FORO AO KK II 2010-0039 In the Matter of Nathan Deal 2 EE IE ot tb tb to tb 2b 2 ot >t ot ot ot ot ot JE EE bb ot tb 2 ot tb tt tt ot ot >t tt KKK KKKKKK KKK KK KKAGGRO HHRBRRHRRHRRRH ARG HRRHOHG FINAL ORDER i i i d fi 6 8 i i i 8 i i i 0 i Consent Order Compliance Agreement >< Dismissal I i GO HRHDOHRR HORROR H RRR RGGRRRHRHD i q § § 4 d § q 8 8 i i i ' FINAL ORDER ; Q 6 f §34 Dentler, Lisa Dentier, Lisa Thursday, July 26,2012 4:19 PM ‘Evans, Randy’ ‘bvinson@mckennalong com! LaBerge, Holly: Murray-Obertein, Elisabeth Dismissats in 2010-0033c and 2610-0039 approved at 7/23/12 Commission Meeting Attachments: __2010-0033c Nathan Deal DISMISSAL 07-23-12 FULLY EXECUTED.pdf, DISMISSAL ORDER 2010-0039 effective 07-23-12 Nathan Deal for Governor, Inc. pdf Dear Randy and Ben: Attached are your copies of the dismissals for case 2010-0033( c ) and 2010-0039 for your files. Lisa Dentler, Confidential Secretary Georgia Government Transparency and Campaign Finance Commission 200 Piedmont Avenue SE, Suite 1402-West Tower | Atlanta, GA 30334 LDentler@ethics.ga.gov | www.ethics.ga.gov Tracking:BEFORE THE GEORGIA GOVERNMENT TRANSPARENCY AND CAMPAIGN FINANCE COMMISSION STATE OF GEORGIA * In the Matter of * Case No.: 2010-0039 Nathan Deal for Governor, Inc. * DISMISSAL ORDER * This matter came before the Georgia Government Transparency and Campaign Finance Commission for a preliminary hearing on Monday, July 23, 2012, pursuant to the filing of a sworn written complaint; the Commission determined that it had not found reasonable ground to believe that the Ethics in Government Act had been violated. Therefore, the Georgia Government Transparency and Campaign Finance Commission ORDERED that this complaint be dismissed. SO ORDERED this 23" day of July, 2012. GEORGIA GOVERNMENT TRANSPARENCY AND CAMPAIGN FINANCE COMMISSION Kevin Abernethy ChairCOMPLAINT COMPLAINT COMPLAINT“james C. Gatewood Chairman Patrick N. Millsaps ‘Member William H. Jordan Vice Chairman Kent Alexander Member State Ethics Commission 200 Piedmont Avenue SO eee Suite 1402 West Tower ORIGINAL RETURNED ~ Alana, Georgia 30334 FROM USPS (404) 463-1980 Not Deliverable As Addressed ! Facsimile (404) 463-1988 Se UnabletoForward | VIA CERTIFIED MAIL. May 26, 2010 Mr. Nathan Deal Nathan Deal for Governor, Inc. 1660 Palmour Drive, Suite AA7 Gainesville, GA. 30501 RE: INTHE MATTER OF NATHAN DEAL FOR GOVERNOR, INC. ‘CASE NO. 2010-0039 Dear Mr. Deal ‘There is enclosed a copy of a written, sworn complaint filed with the Commission alleging that you have violated the Ethics in Government Act (Act). You have thirty days to respond in writing if you choose to do so. For your consideration, the Act and the Rules and Regulatiots of the Commission can be found on our website at hitp:/ethics.georgia.gov. ‘The Commission staff wil review the complaint to determine if there isa basis to proceed. Should the Commission staff determine that there is no basis for proceeding on the complaint under the Act or any other statute within the jurisdiction of the Commission, the staff will notify you and the Complainant thatthe complaint is being administratively dismissed pursuant to Commission Rule 189-2 03(5) without any formal action by the Commission If the Commission staf determines that there is a basis to proceed, the complaint will be brought before the Commission at a scheduled Commission meeting, at which time the Commission will hold an informal preliminary hearing to determine whether there are reasonable grounds to believe that a violation of the Act has occurred. You will be notified in advance of the time and place of the ‘meeting. All mectings of the State Ethies Commission are open to the public pursuant to the Open Meetings law. If you have any questions about procedure or other matters, please contact me at (404) 463-1980, Respectfully, See el. Stacey Kalberman Executive Secretary SK:Imd Enclosure: Complaint cc: Elizabeth Ott, 1975 Nocturne Drive, Alpharetta, GA. 30009pe-%e-2esG0-te8te _Beezgseceoe sa oe cuenvos OL S7auNO, sSBE9884. 85052 99Gwe aicnas‘Oi REALE or/tesa0 02 yas eos AIKEN 2 60008 V9 ‘enaseydyy ALI 9UIN;ION SL6T nO Woqeatgy PECOe VO CEUEDY Saree anne Ve cara aoe CDS 49M0], 189M — ZOPT 9910S wees omenaae) aura ones COBA = soy McKenna Long ve You sata Aldridge. rte a nos sae Dever 303 Peachtree Streat, NE + Suite 5300 + At/en(e, GA 30308 ‘San Francisco "Voi 408.527.4000 « Fax: 404 527-4198, wnu-mekennatong.com Los gets ‘wasinge, 06 FACSIMILE TRANSMITTAL Date: June 4, 2010 Stacy Kalberman, Esq, 404-463-1988 State Ethics Commission | ‘To: Name/Company Fax No. iF | Phone No. From: J. Randolph Evans Phone: (404) 527-8330 Re: Nathan Deal Case No. 2010-0033 ‘Nathan Deal Case No. 2010-0039 Number of Pages (including cover): 3 ‘COMMENTS: RECEIVED VIA FACSIMILE, gun 07 200 TATE ETHICS STONMESSION Confidentiality Notice: ‘The information contained in this facsimile legally privileged and confidential information intended only forthe use ofthe individual or entity gamed above, Ifthe reader ofthis message isnot the intended recipient, you are hereby notified that any alissemination, distribution or copy of this telecopy is strictly prohibited. If you have received this telecopy in rrr, please immediately notify us by telephone and retur the original message 1o us a the address above via the United States Post Office. Thank you UserNo,: 2852 ClienvManer No. 31398.0001 If transmission is unclear or incomplete, please call sender at the above phone number.McKenna Long fa &Aldridge. = 303 Penehuree Stee, NE Ste 5300 + Aanta GA 30308 Los Anger Tah404 527.4000 «Fax, 404.527.4398 Nation 0 wermmekenoalong om 4 RANDOLPH EVANS max aooness aos) 527-8390 sevans€amchennaiorg.com June 4, 2010 RECEIVED VIA FACSIMILE By FACSIMILE (404-463-1988) AND U.S. Matt | Stacy Kalberman, Esq. Fxecutive Secretary STATE ETHICS State Ethics Commission COMMISSION 200 Piedmont Avenue, SE Suite 1402 - West Tower Atlanta, GA 30334 Re: Confirmation of Extension of Time and Response Deadline Jn the Matter of Deal--Case No. 2010-0033 In the Matter of Nathan Deal For Governor, Inc.--Case No. 2010-0039 Dear Stacy: Thank you for talking with me egarding the above-referenced matters. As we discussed, MeKenma Long & Aldridge LLP is representing Respondent Nathan Deal in connection with the above referenced matters. As we also discussed, both matters raise a common issue and hence should probably be handled together. In addition, Respondent intends to file amendments to certain Campaign Contribution Disclosure Reports mentioned in the Complaints so that all of the issues raised, even technical ones, are fully addressed. This letter confirms our conversation on June 4, 2010, wherein we agreed on a deadline of June 21, 2010 for Respondent to submit a joint response to the Complaints filed in both matters. (June 20 twmed out to be a Sunday.) This shortens the response time for Case No. 2010-0039. tt extends the response time for Case No. 2010-0033. And it imposes a deadline for the amended Campaign Contribution Disclosure Reports. ‘Thank you for yout professional courtesy in this regard. Should you have any questions, please do not hesitate to contact Ben Vinson or mte at ny time.June 4, 2010 Page 2 cc: Tom Plank Sincerely, Benjamin J. Vinson RECEIVED VIA FACSIMILE ro STATE ETHICS COMMISSIONJames C. Gatewood Chairman Patrick N. Millsaps Member ‘Wittiam H, Jordan Vice Chairman Kent Alexander ‘Member Stacey Kalberman Executive Secretary - Fee State Ethics Commission 200 Piedmont Avenue Suite 1402 ~ West Tower ‘Alanta, Georgia 30334 (404) 463-1980 Facsimile (404) 463-1988 ‘wonw ethics ga gov VIA CERTIFIED MAIL, May 26, 2010 Mr. Nathan Deal Nathan Deal for Govemor, Inc. 1660 Palmour Drive, Suite AA7 Gainesville, GA 30501 IN. THE MATTER OF NATHAN DEAL FOR GOVERNOR, INC. CASE NO. 2010-0039 Dear Mr. Dea: There is enclosed a copy of writen, swom complaint fled with the Commission alleging that you have violated the Ethics in Government Act (Act). Yau have thity days to respond in writing if you choose to do So. For your consideration, the Act and the Rules and Regulations ofthe Commission can be found on our website at hip/ethies.2eorgia gov ‘The Coramission staff will review the complaint to determine if there is basis to proceed. Should the Commission staff determine that there is no basis for proceeding onthe complaint under the Actor any other statute within the jurisdiction of the Coramission, the staff will notify you and the Complainant thatthe complaint is being administratively dismissed pursuant to Commission Rule 189-2- (03(5) without any formal action by the Commission. Ifthe Commission staff determines that there isa bass to proceed, the complaint wil be brought before the Commission ata scheduled Commission meeting, at which time the Commission will hold an informal preliminary hearing to determine whether there axe reasonable grounds to believe that a violation ofthe Act has occurred. You will be notified in advance ofthe time and place ofthe meeting. All meetings of the State Ethies Commission are open to the publie pursuant to the Open Meetings law. Ifyou have any questions about procedure or other matters, please contact me at (404) 463-1980. Respectfully, a Stacey Kalberman Executive Secretary Sk:tmd Enclosure: Complaint cc: Elizabeth Ort, 1975 Nocturne Drive, Alpharetta, GA 30009Serica pa eT eae e)t) og {Domestic Mail Only: No Insurance Coverage Provided) Foss Doan Fee Carer eS enor : Mr. Nathan Deat Nathan Deal for Goveraor, Inc. 1660 Palmour Drive, Suite AAT Gainesville, GA. 30503 7007 2680 ODD2 2499 ayy9 z Sooner = je items 1, 2, and 3. Also complete ane snytrmeccibaerncriet, momeaeen ta tte a Sen roan tae Mr. Nathan Deal ‘Nathan Deal for Governor, Inc, 1660 Palmour Drive, Suite AAT Gainesville, GA 30501 * cee ronvenacety 7007 2680 OUR 2499 ayy PS Farm 3811, February 2008 Domestic Rat Receipt aryElizabeth Ott ‘ay 2010 i 1975 Nocturne Drive Unit 2102 ; Alpharetta, GA 30009 May 10, 2010 Ra0- COG ‘The Georgia State Ethics Commission Soca ¥ Stacy Kalberman, Executive Secretary 200 Piedmont Avenue - May -2O, 08 Suite 1402 - West Tower Atlanta, GA 30334 Dear Ms, Kalberman: This letter is to serve as a submission to the Commission to charge that Nathan Deal for Governor, Inc. has in fact violated § 21-5-33 by using more than $37,000 in contributions made to a state campaign committee (Deal campaign for Governor) for legal expenses incurred as part of an investigation(s) regarding official conduct of a federal elected official, then-Congressman Nathan Deal. ‘Then-Congressman Nathan Deal was the subject of at least two ethics investigations alleging inappropriate and potentially illegal activities concerning the Congressman’s intervention into a state of Georgia Department of Revenue procurement matter in which the Congressman had a personal business interest, as well as the alleged use of congressional staff into the samme matter. The complaint against then-Congressman Deal was filed on August 26, 2009, A summary of the allegations are found in the March 30, 2010 Atlanta Journal Constitution article (Sheinin): ‘The 138-page report from the Office of Congressional Ethics came seven months after The Atlanta Journal-Constitution reported in August that Deal on three occasions in 2008 and 2009 met with state leaders to question changes the Department of Revenue wanted to make in the way Georgia inspects salvaged vehicles. The AJC found that Deal's chief of staff at the time, Chris Riley, used congressional e-mail to contact state afficials to discuss the plans and to set appointments for Deal. Riley also accompanied Deal to the meetings, some of which were held in Lt. Gov. Casey Cagle's office. Deal and a business partner, Ken Cronan, for 20 years had an agreement with the state that earned the company $1.5 million from 2004 through 2008,‘The Georgia State Ethics Committee May 10, 2010 Page Two according to state records. Deal and Cronan left the state business after changes were made late last year. It has also been reported that the congressional investigation(s) began in the Fall of 2009 and ran through the end of the calendar year. From the March 24, 2010 Atlanta Journal Constitution (Sheinin): According to Roll Call, House ethics investigators “opened only one new inquiry in the last half of 2009. That investigation began in October - the Journal-Constitution reported in December that state records showed [Office of Congressional Ethics] investigators contacted a state office in October ~ and appears to have ended its second and final phase in late December.” Ithas also been widely reported and acknowledged by the Deal for Governor campaign that the campaign expenditures incurred by the gubernatorial campaign were made on behalf of then-Congressman Deal as part of the ethics investigation(s). From the April 9, 2010 Rome News Tribune (AP): Republican Nathan Deal tapped his state gubernatorial campaign account to pay more than $19,000 in legal fees to defend against congressional ethics allegations. It appears that the reported $19,000 amounts calculated from the December 31, 2009 Deal for Governor financial disclosure. The Deal campaign has made the following expenditures for Legal fees: 9729109 0:00 527.22 7/3109 0:00 sig75 | 10/22/09 0:00 | LEGAL FEES 5257.17 {1720709 0.00 | LEGAL FEES 1457.5 1/5/10 0:00 [LEGAL FEES 83778 2/1/10 0:00 [LEGAL FEES 8986.85,The Georgia State Ethies Committee May 10, 2010 Page Three ‘According to the December 16, 2009 Memorandum of Interview filed by Office of Congressional Ethics Investigative Paul J. Solis, Congressman Deal was interviewed on that day and present for the interview were two McKenna Long Aldridge attomneys, Ted ‘Van Der Meid and Randy Evans Based on a review of the March 31, 2010 campaign disclosures for Nathan Deal for Governor, Ine. itis highly likely that January 5, 2010 and February 1, 2010 expenditures were also made in conjunction with the ethics investigation(s) ‘Therefore, the total expenditures for the ethics investigation(s) are $37,079.32. ‘The expenditures made from a committee for campaign for Governor are in clear violation of § 21-5-33, (a) Contributions to a candidate, a campaign committee, or a public officer holding elective office and any proceeds from investing such contributions shall be utilized only to defray ordinary and necessary expenses, which may include any loan of money from a candidate or public officer holding elective office to the ‘ampaign committee of such candidate or such public officer, incurred in connection with such candidate's campaign for elective office or such public officer's fulfillment or retention of such office. (18) “Ordinary and necessary expenses” shall include, but shall not be limited to, expenditures made during the reporting period for office costs and rent, lodging, equipment, travel, advertising, postage, staff salaries, consultants, files storage, polling. special events, volunteers, reimbursements to volunteers, contributions to nonprofit organizations, and flowers for special occasions, which shall include, but are not limited to, birthdays and funerals, and all other expenditures contemplated in Code Section 21-5-33. ‘While it has been usual and customary for campaign committees to retain legal counsel and make expenditures on behalf of the candidate for the office the candidate holds or is pursuing, there is no precedent for a committee organized for the pursuit of a state office (Governor) making said expenditures for legal expenses incurred while serving in as a federal office holder (Congress). Then acting Executive Secretary Tom Plank acknowledged as much in media stories concerning the legal expenditures“The Georgia State Ethics Commission May 10, 2010 Page Four From the April 9, 2010 Rome News Tribune (AP): Ethics Commission acting executive secretary Tom Plank said he could find no precedent addressing the use of state funds to pay legal fees incurred as part of a federal probe. It would simply defy logic, as well as the letter and intent of the statute, for it to be permissible for candidates for office and their state organized campaign committees to ‘make expenditures on behalf of the individual in an unrelated, let alone federal, office. To be sure, the matters before the Congressional Ethics Committee have nothing to do with then-Congressman Deal’s campaign for Governor. In fact, the matters and alleged improper and illegal activities concem then-Congressman Deal's official conduct and that of his staff. There simply cannot be an acceptable argument that the usual and customary use of campaign funds ~ in this case funds from a state organized campaign committee ~ can be used for legal expenditures incurred through the official conduct of a member of Congress, In addition, it has to be noted that then-Congressman Deal had a federally organized campaign committee for Congress for nearly 20 years. An argument could have been made that the federal committee could have made expenditures for legal fees incurred as a result of the ethics investigation(s). But, then-Congressman Deal closed his federal account prior to the ethics investigation(s). Based on the review of the campaign finance disclosures for Nathan Deal for Governor, Inc., the Office of Congressional Ethics, United States House of Representatives March 26, 2010 Report concerning the matter of former Congressman Nathan Deal, and ‘numerous media reports one can only conclude that violations of § 21-5-33 have occurred. I hereby request that the Gerogia State Ethics Commission take up this matter forthwith. [Uagiett, Op- Elizabeth Ott NOTARY PUBLIC ——~S. Fulton County - State of Georgia My Comm. Expires Jan. 1, 2012k2abeth OTF 1S Mectuene pe, UN alon ghaceha GA 30009 The Georgia Slate Ethics Comm: sgion Stacy Kalbec man, Exec Secretary 200 Piedmont Ave Suite 1d0Q- west Tower priate 6& 30334. APIOEE AhthosdbollatatlbalbonddtatdodtatealblRESPONSE FROM RESPONDENT~ McKenna Long any a New Yo ‘Ate & Aldridge.. Phisepia emer 2010-0039 sevtencico 03 Peace Sree, NE» Site 5300» Alta, CA 30308 ‘Los Angeles ‘Tel: 404.527.4000 * Fax: 404,527.4198 ‘Washington, D.C. ‘www mekennalong,¢om DOWD= COB = Seay Argersonn. atrandar\ J, RANDOLPH EVANS seansiGmekennatong, com vaoiyso7 8550 eA ath = ‘= DO0-WO7 = C lizabaAn GV v. NalhoendBeal Keone cat . June 21,2010 Ms. Stacy Kalberman, Esq. :xecutive Secretary State Kthics Commission 200 Piedmont Avenue Sune al, Aono Suite 1416 ~ West Tower Atlanta, GA. 30334 Re: In the Matter of Nathan Deal--Case No, 2010-0033 In the Matter of Nathan Deal For Governor, tnc.--Case No. 2010-0039 Dear Ms. Kalberman; As you are aware, this law firm represents Respondent Nathan Deal, Candidate for Governor. Please accept this correspondence as the response to the Complaint filed by Mr. George Anderson on March 31, 2010 (the “Anderson Complaint”) and the Complaint filed by Ms, Elizabeth Ott on May 24, 2010 (the “Ott Complaint”), We are submitting this response (0 doch Compiaints in accordance with our correspondence to you dated June 4, 2010 in which we agreed on a June 21, 2010 deadline to respond to both Complaints. In short, both Complaints fail to allege any direct, substantiated facts, other than minor technical defects, which could {ead the Commission to conclude that there is any evidence that the Respondent has in any way violated the Ethies in Government Act (the “Act”). As we diset -d, Respondent intends to file amendments pursuant to O.C.G.A. § 21-5-7.1 to address any issues, including the correction of any items that could be construed as inadvertent technica} defects. Accordingly, we respectfully urge the Commission to conclude that there is no basis to proceed on both Complaints under the Act, or any statute within the jurisdiction of the Commission, and to administratively dismiss the Complaints for that reason, In order to facilitate this process, we are submitting this detailed response to address the egal issues raised. In addition, I would be happy to visit with you in person to further address the legal issues inasmuch as they have been the subject of conversations with the Commission and its staff on prior occasions. This response is divided into two sections, First, this response notes the defects in the Anderson Complaint which show chat it has failed to allege facts sufficient to form an actionable claim under the Act, Second, this response recognizes certainJune 21, 2010 Page 2 facts with respect to Respondent and analyzes those facts to explain that Respondent has not violated provisions of the Act. I. THE ANDERSON COMPLAINT IS DEFECTIVE ON I'S FACE FOR FAILURE TO ALLEGE ACTIONABLE FACTS. As a threshold matter, the Anderson Complaint is fatally defective. As its content reflects, it contains nothing more than wild speculation based on hearsay without identifiable sources, save unelear references to Respondent’s Campaign Contribution Disclosure Reports (CCCDRs”) and a single page from Review No. 09-1022 of the Office of Congressional Ethics (the “OCE Report”). These generic speculations are legally insufficient generally, and specifically. In particular, the Anderson Complaint erratically alleges first that Respondent violated Commission Rules 189-3-,01 and 189-3-.04 with various portions of his June 30, 2009 and December 31, 2009 CDRs, and second, that Respondent violated O.C.G.A. §§ 21-5-30.1 and 21-5-30.2 through conduct described on Page 10 of the OCE Report, attached to the Anderson Complaint as Exhibit A. However, no information is provided to specify or even clarify how each aneedote listed correlates to an actionable claim, nor is any specific support provided as evidence for the alleged violations. Rather, the Anderson Complaint baldly identifies a fact pattern from the OCE Report and sandwiches it between a handful of perceived technical defects from two of Respondent's CCDRs. The only “facts” provided in support of such purported “violations” are in fact minor omissions from CCDRs, which will be cured, and an incident unrelated to Respondent's campaign for Governor. Due to the complete lack of actual facts to substantiate the allegations in the Anderson Complaint, it must be dismissed at this initial stage. To do otherwise would allow Mr. Anderson to abuse the complaint process by simply making baseless allegations in hopes that such unsupported claims alone will be enough to cause the Commission to undertake an investigation of the case. As discussed in detail below, the undisputed facts here also support dismissal of the Anderson Complaint because it is clear that Respondent did not violate the Act due to any actions specified in the Anderson Complaint. nh ANALYSIS A. ANDERSON CoMPLAINT While the lack of detail in the Anderson Complaint makes it difficult to know with certainty, it appears as if the two basic allegations are that Respondent did not satisfy the Act's disclosure requirements with specificity for various expenditures and that Respondent somehow accepted an illegal campaign contribution by meeting with state elected officials as described inJune 21,2010 Page 3 the OCE Report. (Anderson Complaint, 1-2). Both of these allegations can be dismissed at this juncture for the reasons set forth below. 1, DISCLOSURE REQUIREMENTS IN CAMPAIGN EXPENDITURE REPORTS, Upon review, the Anderson Complaint identifies the following types of technical defects for expenditures in Respondent’s June 30, 2009 and December 31, 2009 CCDRs: lack of occupation/employer for individual; lack of end-recipient for credit card; insufficient detail for event purpose; insufficient detail for travel purpose; insufficient detail for legal fee purpose; insufficient detail for loan purpose; insufficient detail for equipment purpose; and lack of end- recipient for cash, (Anderson Complaint, 1 & 3-5). In sum, four of the five pages of the ‘Anderson Complaint are used to touch on fourteen instances where Respondent's CCDRs are allegedly defective, Commission Rule 189.2-.01(13) defines “substantial compliance” with the Act as “the requirement that all reports submitted pursuant to the Ethics in Government Act be at least 90% compliant with respect to technical defects.” As applied here, the Anderson Complaint clearly does not point to evidence which demonstrates that Respondent did not “substantially comply” with the Act in relation to such technical defects. Instead, the Anderson Complaint references only fourteen technical defects amongst hundreds of entries that were ultimately disclosed on Respondent's June 30, 2009 and December 31, 2009 CCDRs. Consequently, the Anderson Complaint has not demonstrated less than 90% compliance by Respondent with respect to technical defects, meaning that the CCDR allegations in the Anderson Complaint must be dismissed. In addition, to eliminate any issue in this regard, Respondent intends to file amendments to the CCDRs in question such that any inadvertent (echnical defects should be resolved pursuant to O.C.G.A. § 21-5-7.1 Nevertheless, looking to a few of the specific allegations in the Anderson Complaint, it is clear that Respondent complied with the Act and properly reported allowable expenditures. In each instance below, the Anderson Complaint relays imprecise details of an expenditure, along with wholly unfounded accusations, in expectation that the Commission will commence an vestigation. First, the Anderson Complaint references “candidate travel” with date and amount, then flatly states that there is not full disclosure in Respondents CCDR. To the contrary, candidate travel is clearly contemplated by the Act as an ordinary and necessary expense of a campaign.! ' See O.CG.A. § 21-5-3 ("Ordinary and necessary expenses” shall include, but shall not be limited to, expenditures made during the reporting period for office costs and rent, lodging, equipment, travel, advertising, postage, stafT salaries, consultants, files storage, polling, special events, volunteers, reimbursements to volunteers, contributions to ‘sonprofit organizations, and flowers for special occasions, which shall include, but are not limited to, birthdays and funerals, and all other expenditures contemplated in Code Section 21-5-33.°); OCGA. § 21-5-33(a) (Contributions to a candidate, a campaign committee, or a public officer holding elective office and any proceeds from investing such contributions shall be utilized only to defray ordinary and necessary expenses, which mayJune 21, 2010 Page 4 And in this case Respondent accurately and sufficiently reported the expenditure pursuant to the ‘Act. (See Nathan Deal December 31, 2009 CCDR, attached as Exhibit “A"). As further explanation, Respondent points out that he was employed in Washington D.C. during the reporting period and therefore was required to travel extensively by air between Washington D.C. and Georgia in order to campaign for office. Also, it is common for candidates to attend fundraisers in other states and no provision of the Act prohibits such activity. Second, the Anderson Complaint references “legal fees” with an approximate amount and makes unsubstantiated claims related to expenditures made for legal services, Again, to the contrary, legal services are no doubt considered an ordinary and necessary expense of a campaign and Respondent here accurately and sufficiently reported the expenditure pursuant to the Act. (See id.) Third, the Anderson Complaint references @ candidate loan with date and amount, then raises highly speculative allegations with absolutely no factual support. As before, quite to the contrary, candidate loans are certainly contemplated by the Act and Respondent accurately and sufficiently reported the loan pursuant to O.C.G.A. § 21-5-34(b)(1)(C). (See Nathan Deal June 30, 2009 CDR, attached as Exhibit “B"). Specifically, Respondent disclosed all required information, including the name and mailing address of the lending institution, the name and mailing address of the party responsible for repayment of the loan, and the date and amount of the loar. Fourth, the Anderson Complaint alleges that expenditures to Capitol Hill Club, Capitol Strategy Group, Inc., and Brooks Brothers are not fully itemized. To the contrary, in each instance Respondent complied with the requirements of O.C.G.A. § 21-5-34(b)(1)(B). by identifying the amount and date of the expenditure, the name and mailing address of the recipient receiving the expenditure, and the general purpose of the expenditure. (See Nathan Deo! June 30, 2009 and December 31, 2009 CDRs). Therefore, the bulk of the Anderson Complaint is a simple notation of minor technical defects, sprinkled with nonsensical claims without any justification, that does not present legitimate violations of the Act. Respondent intends to file amendments according to 0.C.G.A. § 21-5-7.1 to cure inadvertent technical defects such as lack of occupation/employer for individual expenditures, lack of end-recipient for credit card expenditures, and insufficient detail for expenditure purpose. Although Respondent is amending these minor technical defects, Respondent maintains the CCDRs in question are in “substantial compliance” as defined by Commission Rule 189-2-.01(13). For this reason, the Anderson Complaint as to these allegations should be dismissed. include any loan of money from a candidate or public officer holding elective office to the campaign committee of sucit candidate or such public officer, incurred in connection with such candidate's campaign for elective office or such public officer's fulfillment or retention of such affice.”).June 21, 2010 Page 5 2, In very bizarre fashion, the Anderson Complaint attempts to articulate a claim under the Act using the fact pattern taken from Page 10 of the OCE Report. (Anderson Complaint, 2). Notably, the OCE report concluded on pages 22 and 23 that it made no finding as to the central issues as reference by the Anderson Complaint. (See OCE Report, pages 22-23, attached as Exhibit “C"), The Anderson Complaint cites 0.C.G.A. §§ 21-5-30.1 and 21-5-30.2, yet utterly fails to show how any action by Respondent would implicate these code sections or any other within the jurisdiction of the Commission. The Anderson Complaint seems to put forth the notion that Respondent somehow received a campaign contribution from a regulated entity, in violation of O.C.G.A. § 21-5-30.1, by attending a meeting with state elected officials as described on Page 10 of the OCE Report. (Anderson Complaint, 2). The Anderson Complaint does not describe what thing or action might constitute such contribution, nor does the Anderson Complaint identify a regulated entity in this scenario.” Without belaboring the point, the Anderson Complaint mentions names and dates from the OCE Report but in no way expresses a valid claim under O.C.G.A. § 21-5-30.1 Notably, the allegations made to the OCE were exactly the opposite of a violation of the statute against contributions by regulated industries. There was no suggestion, finding, or even intimation that the Respondent’s gubernatorial campaign received anything. Similarly, the Anderson Complaint cites O.C.G.A. § 21-5-30.2 in seeking another hook for a legal claim related to a campaign contribution and the meeting with state elected officials as described on Page 10 of the OCE Report. (Anderson Complaint, 2). Again, the Anderson Complaint neglects to describe what tl or action might form a contribution and which public agency is involved. While difficult to imagine, the Anderson Complaint appears to assert that the meetings described on Page 10 of the OCE Report amounted to “the furnishing of office space” to Respondent, Plainly, this is not the case and the Anderson Complaint fails to allege a violation under O.C.G.A. § 21-5-30.2. Once more, the allegations made to the OCE and which the OCE investigated did not involve anything of value to Respondent's gubernatorial campaign. In fact, the OCE allegations were the opposite, It is readily apparent that absolutely no reason exists for the Commission to expend its resources gathering information on alleged campaign contributions to Respondent derived from a meeting with state elected officials that occurred before Respondent even activated his campaign Yor Governor. Furthermore, the notion that Respondent received some form of political benefit * tt should be noted that the meetings referenced in the OCE Report took place on January 28, 2008, June 30, 2008, ‘and March 27, 2009, while the Respondent did not register his campaign for Governor until May 4, 2009, so any allegation pertaining to the OCE Report and a campaign contribution to the Respondent would seem impossible.June 21, 2010 Page 6 from this meeting runs contrary to the essence of the OCE allegations that Respondent received an improper personal benefit not an improper campaign benefit. Henee, reliance om the OCE. Report in this context by the Anderson Complaint is illogical and withaut merit. Accordingly, no good cause exists to pursue any further the allegations contained in the Anderson Complaint at this time, B. Orr ComPLaint ‘As compared to the Anderson Complaint, the Out Complaint clearly alleges that Respondent violated 0.C.G.A. § 21-5-33 by using slate campaign contributions to pay for legal expenses related to the OCE investigation, Two concepts combine to validate the use of Respondent’s gubernatorial campaign funds for the payment of attorneys fees associated with defending Respondent against various charges at both the state and federal level 1, ATTORNEYS FEES ARE AUTHORIZED EXPENDITURES First, it is well established that campaigns can pay attorneys fees with campaign funds, and in fact, the Ott Compiaint concedes this point. (Ott Complaint, 3). It is accepted practice by officeholders and candidates to pay attorneys from campaign funds as legal services are deemed “ordinary and necessary expenses” under the Act. (See foonole 7 supra), In addition, the Commission and its staff have accepted this notion as such legal expenditures have been routinely included in disclosures and filings that have been accepted, reviewed, and analyzed by the Commission without objection or comment, The use of campaign funds for attomeys fees has been the subject of various questions and challenges without a single ruling to the contrary. Instead, when questioned, the practice of paying legal expenses with campaign funds has been widely accepted by the Commission. The practice of using campaign funds to cover attomeys fees in Georgia is consistent With other jurisdictions as well, including the Federal Election Commission (the “FEC”), which has approved such payments for similar purposes, (See FEC Advisory Opinion 2005-11, holding that campaign funds may be used to pay for legal fees and expenses). The payment of attorneys fees is of course consistent with the language of the federal statutes which permit expenditures (See 11 CFR 113.1(g)(1)Gi)(A)).. Such approved instances have included specifically defending against allegations arising out of public service, as those allegations would not exist imespective of the candidate's campaign or duties as an officeholder and therefore may be paid for with campaign funds. (See FEC Advisory Opinions 2003-17, 1998-1, 1997-12, 1996-24, and 1995- 23). The types of activities for wihich attorneys fees may be extended must of course be related to being an officeholder or seeking office. Hence, as contained in numerous filings over the years, disclosures have reflected attorneys fees incurred in preparing and filing disclosure reports (both for the office left and the office sought); giving advice regarding compliance with ethics laws (both federal and state); defending against complaints with the Commission (for actsJune 21, 2010 Page 7 involving official and personal conduct); threatening legal action against third parties (such as the media, opposing candidates, and others); and other legal services performed in connection with the pursuit or retention of elective office. The use of campaign funds for attorneys fees is not a partisan issue. Both Democrats and Republicans incur, pay, and report amounts for such legal services. It is also not a unique or rare claim. Complainants routinely raise the issue. It is clear that campaign expenditures must be made in pursuit of or retention of an elective office. (See O.C.G.A. § 21-5-33 (a), stating that expenses must be incurred in connection with such candidate's campaign for elective office or such public officer's fulfillment or retention of such office). The question then is which campaign pays for such services. ACTIVE CAMPAIGN WAS APPROPRIATELY USED Second, the operative campaign, i.e., the campaign associated with the office sought, is the appropriate campaign to pay attorneys fees incurred while the candidate seeks that elective office. Of course, the essential component for incurring campaign expenses is a candidacy. The statute, O.C.G.A. § 21-5-33 (a), contemplates two possibilities: expenses must be incurred in connection with such candidate's (i) campaign for elective office or (ji) such public officer's fulfillment’ or retention of such office. The question then arising is what happens when a candidate decides to seek a different office. Once a candidate makes the decision to leave the current office, (ic. the decision not to fulfill or retain the existing office), then it appears* under Georgia law that the candidate may not expend funds for the retention of that office. Instead, remaining campaign funds must be spent for the shutting down of the campaign, transferred to a legally acceptable recipient, or returned to contributors. (O.C.G.A. § 21-5-33 (b)(1)(A)-(E); Commission Rule 189-5-.01). For a candidate seeking a different office, this means that the campaign of the office sought, not the office lefi, is the operative campaign fund from which monjes may be spent for the pursuit of an elective office. In the context of the facts described in the Ott Complaint, this would suggest that Respondent's federal campaign needed to begin shutting down once Respondent made the decision not to seek reelection. And, Respondent's current campaign would be the appropriate campaign to pay attomeys fees incurred during his campaign for * Its important to note that Respondent resigned midterm rather than complete his term or seek reelection, * This “appears” tobe the law based on the limitations for the use of campaign funds once a candidate decides not to seek reelection, Neither the Commission nor a court in Georgia has precisely addressed the issue raised in the Ott Complaint. However, based on the direction ofthe Commission regarding the operative campaign for expenses, this ‘would ‘appear’ to be the inevitable conclusion. OF course, in Respondent's context, there would have been a complaint either way. IF Respondent had paid the attorneys fees fom his Congressional campaign account, the allegation would have been that he was not secking reelection. If he paid them from his gubernatorial campaign account, then the instant complaint. ‘The best Respondent could do was seek advice of counsel based on past and current actions by the Commission, the courts, and existing statutes, rules and eases, He did just thatJune 21, 2010 Page 8 Governor. In simple terms, but for his campaign for Governor, these legal costs are not expenses that he would incur. If Respondent stayed in Congress, his Congressional campaign committee would pay them. If Respondent left Congress, but did not run for other office, then the matter ends (since the U, 8. House of Representatives foses jurisdiction) and there would be no reason to contest further. It is only the pursuit of the Office of Governor of Georgia that makes the current expenses and attorneys fees necessary. In summary, Respondent's gubernatorial campaign account was the correct account to pay these expenses. It is the active campaign. ‘The legal expenses derive from his decision to seek the Office of Governor. Such action is consistent with the practices and rulings of the Commission and courts. Consequently, Respondent's state gubernatorial campaign fund became both the operative and appropriate source for the attorneys fees and all expenditures for the pursuit of elective office going forward. The bottom line is that the payment of legal fees as alleged in the Ott Complaint is appropriate because the legal expenses are connected to public service, not for personal use, and the active campaign for which Respondent is pursuing office is the state gubernatorial campaign. Accordingly, no good cause exists to pursue any further the allegations contained in the Ott Complaint at this time ML Conclusion For these reasons, Respondent Nathan Deal respectfully requests that both Complaints be dismissed administratively pursuant to Commission Rule 189-2-.03(5) without further inqui Please do not hesitate to contact me at any time if I can be of further assistance in this matter. Sincerely, J. Randolph Evans To Randy Evens (ufexpres provecins) Benjamin J. Vinson By ATLANTAS230451.7orm (eR= Cee v8 05.08° First Class Mail McKenna Long & Aldridge... ATTORNEYS AT LAW SUITE 5300 + 303 PEACHTREE STREET ATLANTA, GEORGIA 30308 To Ms. Stacy Kalberman, Esq Executive Secretary State Ethics Commission 200 Piedmont Avenue Suite 1416-West Tower Atlanta, GA 30334 6¢¢64¢<EXHIBIT “A”FILER ID. C2nomnOU08E State of Georgia Campaign Contribution Disclosure Report 1. Report Fype is being made on Behalf of: Fling Ortce Use Conia Pa ea ‘nt Original Report | (2009000086 1710 9.6 poe Nathan Deaf for Goveem Nathan Deal Use Earlier of Post Governor Mark oF Hand Delivered Date 3. IMetifing and Contact Enferm: (1) Nathan Deal (2) aL 2009 (3) PO Hos 2495 _Guinesill GA 30503 2) (770) 297-0011 (5) tea Cnaacont ha ak amp a as (7) Chaierson: Philip W witheit Treasurer: Wes Smith 4, Period for which you arr Reporting TF femom S000 a June 30. 2009 a 6 days before General ae Een 1 se en Sit etre Spi Primary Run-OW 2009 : fyb Si December 31,209 [O rewon: 2009 October 25.2009 C1 dew. 31. 2000 ooo00 The electronic filing of this document constitutes an affirmation that the statement is rue, complete, ‘and correct. As per modifications of the Ethics in Government Act, fling a separate notarized affidavit is no longer required. See O.C.G.A. §§ 21-5-34.1{e) and 21-5-50\e). ‘Campaign Conurtuton Disclosure Report for 2009 Devember Ist - Now lection Wear - rising Llecromialy Pt tthe Ste Eies Comte an 1772010 9.06:S6M Conia € 20 NHNIS624699i FL 1: C2o09noNs6 State of Georgi n Contribution Disclosure Report I 1 [intave ‘Cash Amount ‘ie following contributions neuding Common Sours, to report 2 roa comittions pres iousy ponte Crop a na] amt of a Hemizedwontibaions weeeive in is Fepowtng pri whi ane sod on the "emized Contributions pe sve 855802 5] Attanns rscne ths poring pei. sH00 3] rout amount oF investments sod this eporting peri 54] Tova amount oF cash dividends and imterest pal out his reporting period a Tolan Tall separate Gontibatons oF Tes than S107 eee Ws + ecpoaing period and not sted n the “Hemized €otibations' pas Cama Sac me elon hm Cons 13000 Santas > foal comttons epone this porting period 4 bine 3:4 3a M4) $30.040.32 S608 38.64 Tosa conto To de 6 [uine2 5 sysy7.9 EXPENDITURES MADE > [tttave: The following expenditures to report § Ha expenditures made ad reported prior this reporting peiod oD Syren @__} Total amount ofa nenized expendies made in ths reporting pid which ae ned on the “emized spends" age suo $16,09008 ia anion ofall Sepa epee oT xs Man STOT 00 each tat wre ade ths roporting peri an not tsted on the “emnized Eypenditres” pase sooo srs Tr Tora expends reported iis poring peo ine 101 sooo si16.307 Te | Fos expendinres vo date a agree tines 11 iene INVES 13 J Amount of vesoents at the being of this veporting period so Tova amount oF investments at the close ofthis poring period S90 5 Nei Balance On Hand Line 6-12 + Hy soa anypaign Conibution Disclosure Rept for 249 Devemnber 31st - None lection Var - Orginal Ltroialy Fed With The Sate Ethics Commision an 17 20109306 S6PAT —- Cunvemation 2000008621699State of Georgi Campaign Contribution Disclosure Repo Outstanding Indebtedness Primary 2010 Indebtedness 1 J Owsantingindebrediess at the Beginning oF 1 report ine this reporting petion son © [ramen npn pent deena eps oom 5 Total indebredness at the close of this reporting period, line 1=2+3-4-5-6) Campaign Contribaton Disslosure Report for 2009 December Ist Nwicection Wear - Original nical Filed with the State Eics Const ums 1 7 2010, 9S06:S6PM = Canina #C20B00H08624609: FILER 1D: Conon State of Georgia Campaign Contribution Disclosure Report Itemized Contributions Must received by single contributor for which the aggregate tai SIOLAD oF more ki Fall Name of Contato Maiting Adress Received Date |a. Occupation & [Election | Cash Estimated Vat Station ot Camantee tay) Contribution type [b-Employer Caste | amount scription $8 Investments LLC 111092009 | temaion = ssn S000 PO Hox 408 Meneiry | Rese ” Cartersville. GA 30120-1719 3 en Abbot fi Wank opna2u9 Presiden =a S000 sou PO tos 3466 Monetary | ABHA'CATCompny | POMN Augsta. GA 30914-3466 tos Almaty. J. Brady 1to2009 Wo tate Saks pa in we 2745 igh Visa Pinte Monciary | Sortie Rey | Poms Gainesile.GA SUSU ACB URIINDMEE fs maton Po siasu0 sua PO Box 15027 Monetary | Rewtesed ay Augusta, 30919 smo Acre. Charis iaas20y [a seniorv.r evo s20000 aaa 317 Lakeshore Drive Monetary | tStesGo eats | Psy Lagrange. GA 30280 Syucm Aree. W. Richa Hrus-2009 wn 2 ny ‘0 1223 Rodale Monetary | PAswe oi Cu Wma Toccoa. GA 30877-1410 Actas Transl and Storage Co, Vanaw9 | ateoaton » St.100.00 so. Ine Moncary | Rete i 795 Gicorgin Avenue nisin Gainesville. GA 30801 eytosed Aadivon, Ores 932000 [Reson Sake ane S500 S000 441 Holly Dr Monetary A Pm Gainesile. GA 30801-2143 tora ropes | Canypaign Contribution Disclose Repost fr 209 December 31 - Non-kletion Year - Original Lcetronialy Fed vith he Sate Lthis (anaron n 3010 06:36PM Copration 2C 000624609~ 159 Hevage Drive Sse rem Clermont, GA 30527-1925, ae Geant. G8 30827-1928 & ‘ana GA 30303 nea Ts ee os ssmn00 000 Tog 20 Site 9A tain Campaign Cony Electronically Mod hth buon Disclosure Rept for 2009 December 31st Non-Llction ¥ ‘Stas Lies Commisvion oh T2010 9s6:sabMt Ovi ‘Conrmation 20008624699~“ AM, tes wire [anne Stoww.0 som 6825 lolland Dave Moncury | Rt . Coming 4 50040 Align Siany ox202009 a trailon ‘Sho so. POR $91 Nonsty | Alia st Duin, GA St Sata ‘lpn MD. Lawrence M 1rAK6 2009 | Pyscn ao sou 0.0 1 Faineay Deve tongary | Stnpkyes | Pres Comat. GA, 30117-4134 ‘Aion, Dena corso [= Homevake = srs. ‘00 D515 N Oaks Dr Menctry [BNA " Giese. GA. 30806-1892 ‘Apsin. Heary oxza2009 | Psion swe 0m S000 1 Eagleton Court Moneta YN SatrElyes | Pray Aut, Ga 30908-1803 ‘Alston. Marvin iam — [a orictannes [26 S00 ‘0.00 613 Limon Road Monetary | - Een tam rm deri, GA S108 Andeson Soba Faye oxi2n09 | Homemaker oie sin so Mi Anderson Ros Monaary — [D®A rms Ejay. GA 30536 Anderson, Johnie Faye 2152009 |= Honeralor Si sow AL Anderson Road Moncay | A lips. GA. 30536 Anderson HL A.M 117162009 [a Physican sn S250 soa 4260 O1 Club Road E Moneiary | SetFEmplaycs | Fora Macon. GA 31210-4740 Anderson Farm 123172009 | Inooraton coe an ae 160 Lonisile Road Monetary | Reese “ Groveton, GA 20813 f tsoonaton Requested ampaign Conibation Disctosine Report for 2008 December 3s Non-Letion Year «Orginal Electronically Fie ith the Sia hes Canasion ons 172010 "946: S6PM == Confimion 9200000862409~ on Anderson Hoe Howse 1231 2009 | tation Shao soo 160 Louisville Road Monetary Rejussed Groveton, GA 308 ieee Andrew R. Algood DMD FC wsn62009 [a Demos Shana soa 4491 Furys Ferry Root Montary [Set mpoyed Augusta, GA 30907 Andrews, James W 1292009 [a sor ssi suo 738 W Church Stet Monetary | ® Cif Sanders Sandersville GA 31082 Aare, dames W rrax2q [a ata S125) su00 738 W Church Sts Manciry CHS af Saneositle | Sandersville. GA. 31082 Annis, 221° ‘ox722009 [a Po tanazemen [00 os So PO Bos 212909) Monetary BeAdhaneed Servecs, | #0 Agusta, GA 30817- Ine postal. John ovnazu09 fa Rowe wn Eom aaa 425 Armstrong Way Monetary Reto Fran Evans, GA. 30K09. ‘Aarendae. Gus 1282009 Ja trecune sn 00 0.00 POBox 538 Monetary | b-FiKlate Fame Baldwin. GA 3051 Associates in Laboratory Medicine 123172009 | tomnation ‘200800 Sai Ine Moneiary | Requesed PO Bos 127 .Inaion Dalton, GA. 30722-0127 Routed ‘ATandT 1o920» | tornation “ae ena Sana P.O, Box SOKO1T Moneary | Rewested Friar Orlando, FL 32859 be ntormtion Hogue Aton. Troy. wiasam9 | Rowe Pr esnaet a 1150 Dogssood Dave Moneury | ® Xetiod Groorsbore, GA 30632 anaixs Conitaion Disclosure Repowt for 2008 December 31s tleevonialy Ped with Se thes Comm Non-Llsstnn Yea -Origival Hesiow on 17 2010" 906 S6PAP == Coninmation C2299“A Aina Compa Induscs tne va 2me [a tion aie ssi sn PO Box 2537 toners | Bees ns Gaile. GA, 50808-2587 2 inn ‘Avian Technology Ineratonl LLC tw192009 [toma a sso sow PO tos 2092 Mowewry—Rovened ms Gaines, GA. 30505 a Bogiy. Ait tw162n09 [a tour 0 25000 soon 5895 Post Rd Money | Camming. GA 30080-6077 Bagot ne 11142009 |= Famer ne ‘aon ‘09 20 all Raa SW Mosciary | Sif tspigd ‘mn Cove Sing. GA SOI Bape! Joanne v.09 2009 [was wn ‘s0000 oan 78H Crags Ro Monctry J Rei me [AW GA 30510 Bagwell. Joanne wv202009 [a teinad 0 Sr a 7880 Crags Rood Monetary |B Ried ry Ally, GA. 30810 Bley. Jon reaname — [cw dae S000 soo 6802 Gaines Remy Road Monetary | shin iy Flowery Branch, GA 30582 Bley. Mike ww200 [a tar se arm con 212 New Bathe Chute Rood Moneta |. und me Davesomile, GA OSHS Ble. Pip Hates oviano9 a Pym “wo San it 208 N Castle Rd Monetary -SefEnntnes | Psu Dalton. GA. 307208008 Baker Chats Ta v201 [Ck sun a co A715 Log Calon Ra Monsiay | Own Gaines. GA 3008-5259 fa cous anpsign Contribution Disclosure Repo lox 2009 December Sst - Now-Lleetion Year - Original Ltocionically Pied wa he Ste Lthies Conia ons 72000 9:06 S6PM = Contin 5 2U0SH001 8624098A Baud kanes w292M fawn a ssn soo 114 Kes Dave Monctiry | Kowa én Miva do Smo ssn, Lary 3 ww2620m [Saco tae [208 eran ea 716 Goorge Bares Rd Monetary | PFA Cay vo Murayville. GX 305641323 Caner alin, Lary A Taii20% — [asic mie |» siamo an 7076 Gg Hares RA Moncany, [Pe tbls a Murra Gis 308611828 Coser Wal Ssot T20K209 |e ATrn Sto. S00 PO tos 3280 enery | Sevan Atenas | Poy Giese. GA. 30805-3280, to ant. Jk TeavamI [wos a SL si PO Bos 628 Monctay [SiC Lphyst Daton, Ga 30722.0624 Banks. Wiliam © roam — [arms " sis0.00 aa 530 Zebulon Road 60 Monetary | Rowe im Macon. GA 512109150 Baik. Win «Pasian ou am aia 301 Lake Faves Dre fe strtiphgca | ms Agusta, GA 30909 aril. Witham 7a [atin ne 100050 ‘soo 5011 Lake Forest Drive Monomy—{ StF rus August GA 3099 Bare. David watz — [a dens ae S000 aD (69) Mouton eas Rood Moncury—[ Settemplgss | Pn Clestan, Ga 30528-0010 Bore Miche ox242000 [tm an sso soon 1070 Vivia Road Moncigy JP snd vm Hiawassee GV 30546. poset ‘Campaign Contbation Disclosure Repo fe 2009 Devernber Sst Lsommmiealy ed withthe State Lshics Commision 3 Nonsuiction Year Orizinal T2010 o:S6PM = trmation 5 20090000562 1609~ Bayrett. Michss gor 2m [a tmanse vn son sos00 eo 7M Vista Road ‘Monetary Haetand Higgs. GA. 30546. Asis aot. Mice Trir2a atic rgor [ane ‘toon ‘sou 1070 Vista Road Monetary bert cs Hiawassee, GA 305A tee baron J Prank 1282009 [tone me ‘500.00 aa 1) Last Sool Avenue Monctiy Ramat Suite 100 Rome.GA 30160 arrose. Robert | rrwemy [a Rent on 250 30.00 ‘0H im Crow Ra — Renna Pras Fiowes, Branch, GA 30542-2508 arto Provast 12262009] Innasion wwe sm 08) S00 PO Hos 200867 ms Ropucsad ina Cartersville, GA. 50120 mati BAT Associates ne E2009 | atom wn 400.00 30.00 5151 Brook Hollow Parkway Monetary) Ratios Pha Suite 250 tation Noretoss, GA 30071 Routed atl, Paul or 14200 Ya tanker SH000.00 si.00 PO Bow 3877 ‘Monetary [Rs " Canorsile, Ga 30120 Boalt fe. Thomas Hov20 [a Rete sun Shon 0 sino PO tos 251 Monetars TF Bea Cate. [Pom West Point, GA. SI833- Bourdon, Clit os 13200 Ps anomns| a ea 304 Fhghway 136 W neat be Self mph Fm Dawsonille GA, SSH Beurden, Clin oe 20m Pa mums Stow uo) $0.00 9308 Highway 136 W Dawsonville. GA. 308M- Monetary bh Seirtamieed Campaign Contnbuton Disclose Repon for 2009 December 31st - Non-Lleston Year - Origins! sly Wo wah the Slate Edbics Comms i 17 20106: SoP Comfnmain =€ 200862 1699