April 15, 2014

CASE NO. EI-14-0126

Florida Department of Law Enforcement OFFICE OF EXECUTIVE INVESTIGATIONS

Jennifer Carroll: Allied Veterans of the World
INVESTIGATIVE SUMMARY
INVESTIGATIVE PREDICATE
In February of 2013, the Florida Department of Law Enforcement (FDLE), Office of Executive Investigations, received information from the Seminole County Sheriff’s Office (SCSO) regarding the relationship between then Lieutenant Governor Jennifer Carroll and Allied Veterans of the World (AVOTW). At that time, AVOTW was being investigated by the SCSO for operating alleged illegal gambling establishments throughout the State of Florida. During the course of the investigation, the SCSO determined that Carroll received compensation from AVOTW beginning in 2009 and ending in 2010, prior to the time that she became a candidate for Lieutenant Governor.

INVESTIGATIVE FINDINGS
Pursuant to a review of the information received from the SCSO, FDLE determined that Carroll was involved in a business relationship with AVOTW while serving as a Florida Representative. Records reflected that Carroll operated a consulting business identified as 3N & JC Corporation, which received $96,000 from Allied Veterans Management Group, Inc. between September 2009 and November 2010 Jennifer Carroll Interview Carroll was subsequently interviewed by FDLE regarding the nature of her business relationship with AVOTW. During this interview, Carroll stated that she was contractually hired as a consultant regarding the public relations aspect of AVOTW. Carroll indicated that, while employed by AVOTW, she was under the impression that the business was being operated in compliance with the requirements defined by state statute for “sweepstakes.” Carroll was also questioned regarding the potential conflict of interest regarding her sponsorship of House Bill 1185 (2010 gaming legislation). Carroll explained that she, with assistance from
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April 15, 2014

CASE NO. EI-14-0126

the Florida Department of Agriculture and Consumer Services, drafted legislation that would have affected the gaming promotions industry, including AVOTW. Carroll indicated that it was not her intent to sponsor the bill. She stated that the bill was mistakenly filed by her staff, but later withdrawn at her request. Carroll advised that she did not have any concerns regarding her relationship with AVOTW because she did not view them as a gambling operation. She further advised that she did not believe that her work as a consultant conflicted with her work as a legislator. AVOTW, Jerry Bass and Johnny Duncan Interviews FDLE also conducted interviews with Johnny Duncan and Jerry Bass, former and current National Commanders of AVOTW. At the time of these interviews, both had pleaded guilty to charges brought against them by the Florida Office of Statewide Prosecutor for running an illegal gambling operation. Duncan and Bass provided similar information regarding AVOTW’s association with Carroll and indicated that Carroll was contractually employed by AVOTW as a public relations consultant during late 2009 through 2010. Bass and Duncan explained that Carroll’s hiring was suggested to them by lobbyist Carlos Cruz who, at the time, was employed by AVOTW. Regarding the 2010 draft legislation, both Duncan and Bass indicated that they were not involved in drafting language for any potential “gaming” legislation, nor were they aware of Carroll’s involvement in the drafting and sponsorship of House Bill 1185. State Financial Disclosure Forms FDLE also reviewed Carroll’s 2009 and 2010 state financial disclosure form(s). FDLE determined that Carroll’s 2010 form(s) did not accurately reflect her total compensation from AVOTW. When this discrepancy was brought to her attention, Carroll explained that, because she did not have any significant financial change between 2009 and 2010, she copied and placed the 2009 information on her 2010 financial disclosure form in error. During the course of the FDLE investigation, Carroll’s attorney provided FDLE with her 2010 federal tax information. A review of Carroll’s federal tax information also revealed that Carroll did not accurately report the compensation she received from AVOTW to the Internal Revenue Service. During the course of the investigation, Carroll took steps to amend both her 2010 state financial disclosure form(s) and her 2010 federal tax return.

CONCLUSIONS
Based upon information obtained pursuant to FDLE’s investigation, Carroll’s business relationship with AVOTW and her subsequent actions do not appear to violate any criminal Florida Statute. Carroll’s actions and the inaccurate information presented in her 2010 state financial disclosure form(s) may, however, be more appropriately addressed by the Florida Commission on Ethics, and this matter will be referred to them for review.

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