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ARKANSAS ETHICS COMMISSION

910 WEST SECOND STREET, SUITE 100 LITTLE ROCK, AR 72201

Phone (501) 324-9600

Toll Free (800) 422-7773

CITIZEN COMPLAINT FORM

The undersigned person files this complaint and requests that the Arkansas Ethics Commission conduct an investigation concerning the facts and actions detailed below for the purpose of determining whether or not there has been a violation of laws under the Commission s jurisdiction.

1. Identify the person you are complaining about:

Name:

Jason L. Brady

Address:

3018 Dapple Gray Road

Benton, AR 72015

Lobbyist/public official

Position or Title:

Phone: (Home)

(Work)

: 501-682-3835

2. State in your own words the detailed facts and the actions of the person named in section 1 which

prompted you to make this complaint. The brief space provided below is not intended to limit your statement of facts. Please use the back of this form or additional sheets if necessary. Include relevant dates, times, and the names, and addresses of other persons whom you believe have knowledge of the facts.

Jason Brady in his capacity as a registered lobbyist for the American Cancer Societ Cancer Action

Network knowingly and willfully filed false lobbyist reports for the period July 2013 through

December 2014. He conspired with public servant Dennis Milligan to ensure his name and

activities on behalf of Mr. Milligan were not reported in campaign reports which, in-turn, would

have linked Mr. Brady to the false lobbyist reports he filed. Specifics and proof are attached.

3. Attach or make reference to any documents, materials, minutes, resolutions or other evidence which

support your allegations.

State of Arkansas County of

I swear or affirm, under penalty of perjury, that the facts set forth in this complaint are true and correct to the best of my knowledge, information, and belief.

Subscribed and sworn before me this

Signature:

day of

,

20

Print your name:

 

Notary Signature:

Mailing address:

 

My Commission Expires:

Phone:(Home)

 

(Work)

Approved by the Arkansas Ethics Commission

Revised 06/01

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I allege American Cancer Society Cancer Action Network (hereafter ACS CAN) lobbyist reports filed by Jason L. Brady purposely omitted, concealed, and falsified information required to be included in his lobbyist activity reports covering the period July 2013 through December 2014.

Mr. Brady while employed by ACS CAN as their primary Arkansas lobbyist concurrently served as campaign manager for Saline County Circuit Clerk Dennis Milligan, a public servant running for Treasurer of State, for two elections. Mr. Brady performed campaign management duties while an ACS CAN lobbyist, using his ACS CAN office, furnishings, computer and equipment, telecommunications – to include the telephone conference call system, and e-mail system. Mr. Brady conspired with Mr. Milligan not to identify him in campaign filings, as required by law, because his actions were in blatant violation of ACS CAN employee ethics rules. Exhibit 1 is Mr. Brady’s lobbyist registration for 2013 and 2014. Exhibit 2 is an extract from the ethics code.

Exhibit 3 is a March 11, 2014 email from Mr. Brady to campaign contractor Your Ad Team (YAT) Shaun McFarland, and campaign treasurer Ulrich “Rick” Meyer directing a violation of Arkansas campaign finance and contribution reporting law. In this email Mr. Brady said,

Shaun … would you please include this bill for $308.96 in your next bill to the campaign for reimbursement. After you receive a check from the campaign, would you mind reimbursing me?

Rick … sorry to ask for this, but as you know, for my job security, I can NOT be listed anywhere on a campaign contribution report.

Allegation 1. Mr. Brady’s lobbyist reports did not provide a detailed statement of any money loaned or line of credit established for this public servant’s campaign. Mr. Brady was empowered with unquestioned campaign finance decision-making authority by Mr. Milligan in a July 27, 2013 email to Mr. Meyer (exhibit 4). Mr. Brady purchased Facebook campaign advertising on at least four occasions using his personal Facebook account #156971705 and paying with his personal credit card. By Mr. Brady’s direction, expenditures of $1,962.79 which constituted “money loaned or a line of credit” for a public servant were reported in campaign reports as being made by Mr. McFarland dba Your Ad Team (hereafter YAT). Mr. McFarland reimbursed Mr. Brady with company checks obtainable by subpoena. When campaign emails were made public in April 2015 and Mr. Brady was exposed, Mr. Milligan amended several campaign reports to reflect Mr. Brady’s purchases on their behalf. Subsequent September 18, 2015 amendments also listed Mr. Brady’s campaign expenditures and reimbursements thereto.

a. Exhibit 5 is evidence of the first occurrence to conceal a $308.96 campaign expenditure and reimbursement to Mr. Brady under the guise of a campaign expense incurred by YAT. The campaign report for March 2014 (extract below) reports the campaign paid YAT with check #1276. The amended campaign report for March 2014 filed on May 22, 2015 (exhibit 6) reported the reimbursement to Mr. Brady who did not report this transaction in his March 2014 lobbyist report (exhibit 7).

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Original campaign report entry:

3 Original campaign report entry: Amended campaign report entries: b. Another campaign expenditure made by Mr.

Amended campaign report entries:

campaign report entry: Amended campaign report entries: b. Another campaign expenditure made by Mr. Brady, invoiced,

b. Another campaign expenditure made by Mr. Brady, invoiced, and reported as a YAT

expenditure occurred in April 2014 (exhibit 8). The original April 2014 campaign report lists a

$2,705.26 payment to YAT with check #1277 but the amended campaign report filed on May 22, 2015 (exhibit 9) lists a payment to Mr. Brady who did not report this transaction in his April 2014 lobbyist report (exhibit 10).

Original campaign report entry:

report (exhibit 10). Original campaign report entry: Amended campaign report entry: c. There are several Facebook

Amended campaign report entry:

campaign report entry: Amended campaign report entry: c. There are several Facebook credit card purchases by

c. There are several Facebook credit card purchases by Mr. Brady in May 2014 totaling

$402.26 shown in Exhibit 11. This expenditure was not reported in Mr. Brady’s May 2014 lobbyist report (exhibit 10).

Allegation 2. Mr. Brady did not provide a statement or otherwise disclose his direct business association with this public servant. That relationship is evidenced by exhibit 4 and the ACS CAN investigate report summary at exhibit 12.

Rules on Lobbyist Registration and Reporting in § 519 says, “Pursuant to Ark. Code Ann. § 7-6- 218(b)(4)(D), the Arkansas Ethics Commission may report any person found to have violated any of these rules to the proper law enforcement authorities. In the interest of enforcing ethical lobbyist behavior, we ask this be done following investigation confirmation of allegations.