JACK CAMPBELI, “unset Lamm SES9B2SEO STATE ATTORNEY A Si y,.- — KEE FROM: Eddie Evan$,fecheFal Counsel, Office of the State Attorney, Second Judicial Circuit SUBJECT: January 16, 2020 Referral from the Florida Department of Law Enforcement (FDLB) regarding the Florida Office of Financial Responsibility — Preliminary Inquiry On January 16, 2020 the Office of the State Attorney for the Second Judicial Cireuit received from the Florida Department of Law Enforcement (FDLE) the FDLE Briefing Memo along with a thumb drive of related documents FDLE had received from the complainant or his then attorney. At your request, I reviewed the materials and discussed with the complainant's then attomey the complaint. Over the past sixteen months, I sought and received additional documents from him. ‘The claims of criminal behavior were mainly made in civil complaints and amended complaints filed in complainant's civil lawsuits involving his prior employment with the Department of Financial Services. The other documents FDLE forwarded with its briefing memo were from the complainant as support, for the allegations in his civil complaints. As the complainant's civil suits progressed, requests were made to the complaint’s attorney for any additional factual evidence in support for the allegations. Some additional items were received, mainly amended complaints of the original civil suits along with some supporting documents. The supporting documents were conclusory in nature or subject of multiple interpretations, The complainant had a change in attorneys and contact was made with complainant's new attorneys on April 15, 2021 as to whether there was any additional documents or factual information they wanted to provide to be considered in this matter. They requested they be given to the end of April 2021 to provide any additional information. No ‘additional information or documents were provided. Page 2of2‘The complaints and amended complaints in the civil suit make allegations of crimes and purport to substantiate them with bits and pieces taken from the supporting documents, However, a though review of the materials provided, when taken in context and as a whole, as opposed to the selective excerpts in the civil complaints, indicates there is not sufficient evidence of bribery or corruption by threat to warrant a formal criminal investigation into the allegations made in the complainant's civil lawsuits, ‘The complainant also alleged a criminal public records violation for the release of a sexual harassment complaint(s}. Whether there was any public records violation is questionable, but there is no evidence provided that any alleged violation was done with criminal intent. The release of the documents was done after a deliberative process that involved the vetting of the release of the documents by the general counsel's office of the Department of Financial Services. Such actions indicate the release of the documents was made in a good faith attempt to comply with the sometimes nuanced public records laws of Florida and not with a criminal intent to violate the public records laws. Finally, the victim in the sexual harassment complaint was contacted, through her attorney, and after discussing the issues with the victim's attorney, there ‘was no objection to closing the investigation without criminal charges. ‘Therefore, absent additional evidence of a crime, I recommend this matter be concluded. Page 2of2