COMPLAINT ON ONE , ‘JULIE M.

SAMPLES’ IN THE STATE OF SOUTH

CAROLINA , ACCORDING TO THE ‘SOUTH CAROLINA CODE OF ETHICS AND
RULES OF CONDUCT.

The following Complainants, herein placed by their signature to this document have filed
with the S.C. Ethics Commission a Complaint against one ‘Judith M. Samples’ for Violations
of S.C. Code of Laws under Title 8, - Public Officers and Employees, CHAPTER 13 -
ETHICS, GOVERNMENT ACCOUNTABILITY, AND CAMPAIGN REFORM.
Whereas the S.C. General Assembly passed Ethics Law and spelled out Rules of
Conduct of Public Officers and Employees:
Whereas , the S.C. Ethics Commission has spelled out the following :
‘Rules of Conduct General Information’
‘All public employees, public officeholders, and public members are expected to adhere
to and follow the Rules of Conduct as outlined in the Ethics Reform Act. Anyone who is found
guilty of violating these rules is subject to prosecution by the State Ethics Commission and the
Attorney General's Office.’
And furthermore under : S.C. Code of Laws
ARTICLE 7 ; Rules of Conduct
SECTION 8 13 700. Use of official position or office for financial gain; disclosure of
potential conflict of interest.
COMPLAINT-1, VIOLATION-1;
S.C. Code of Laws: Section 8-13-700 (A) No public official, public member, or public
employee may knowingly use his official office, membership, or employment to obtain an
economic interest for himself, a family member, an individual with whom he is associated, or a
business with which he is associated. This prohibition does not extend to the incidental use of
public materials, personnel, or equipment, subject to or available for a public official’s, public
member’s, or public employee’s use that does not result in additional public expense.
COMPLAINT-2, VIOLATION-2 ;
S.C. Code of Laws Section 8-13-700 (B) No public official, public member, or public
employee may make, participate in making, or in any way attempt to use his office,
membership, or employment to influence a governmental decision in which he, a family
member, an individual with whom he is associated, or a business with which he is associated
has an economic interest. A public official, public member, or public employee who, in the
discharge of his official responsibilities, is required to take an action or make a decision which
affects an economic interest of himself, a family member, an individual with whom he is
associated, or a business with which he is associated shall:

(1) prepare a written statement describing the matter requiring action or decisions and the
nature of his potential conflict of interest with respect to the action or decision;
(4) if he is a public official, other than a member of the General Assembly, he shall
furnish a copy of the statement to the presiding officer of the governing body of an agency,
commission, board, or of a county, municipality, or a political subdivision thereof, on which he
serves, who shall cause the statement to be printed in the minutes and require that the member
be excused from any votes, deliberations, and other actions on the matter on which the potential
conflict of interest exists and shall cause the disqualification and the reasons for it to be noted in
the minutes;
(5) if he is a public member, he shall furnish a copy to the presiding officer of an agency,
commission, board, or of a county, municipality, or a political subdivision thereof, on which he
serves, who shall cause the statement to be printed in the minutes and shall require that the
member be excused from any votes, deliberations, and other actions on the matter on which the
potential conflict of interest exists and shall cause such disqualification and the reasons for it to
be noted in the minutes.

The person in this Complaint, Julie M. Samples, was involved in a lawsuit Case number
2016CP2605531, as a Defendant, along with the following other Defendants. Ie; James D
Keene III & Dianne L. Tinney, Re-Max Southern Shores (Samples employer), William G
Nichols III, Dunes Realty, Inc. dba Dunes Realty Sales , Gary A. Blake, Beyond Contracting,
Inc., The Town of Surfside Beach and Stewart Title Company aka Stewart Title Guaranty
Company. This Case was filed on 08/24/3016 in the 15th Judicial Circuit , in the Court of
Common Pleas of Horry County.
 Prior to Case Number 2016CP2605531, being filed, Julie M. Samples, as a Candidate for
Public Office, misrepresented herself to the voters, and stated publicly in a Public Forum for
Candidates for office, and stated to the voters, that she was not in any way the subject of a
possible or pending lawsuit against herself or the Town of Surfside Beach. This lie and untruth
by, Julie M. Samples, garnered sympathy for the candidate, Julie M. Samples, and as a result,
Julie M. Samples, won the election to public office on 08/23/2016 and financial compensation.
In essence , the outright lie and misrepresentation and withholding of a material fact to
the voters of the Town of Surfside Beach, that Ms. Samples was a party to a pending or possible
lawsuit against herself and the Town of Surfside Beach, led to, Julie M. Sample gaining the
Office of Council member of the Town of Surfside Beach, and the case was filed the day after
Ms. Samples was elected. Julie M. Samples, had prior and actual knowledge of the pending and
possible lawsuit as she was sent a letter regarding the possible and pending lawsuit on
December of 2015 from the Law Firm of Thompson & Henry, PA. ie; Phillip C. Thompson, at
1300 2nd Avenue, P.O. Box 1740, 29528 , Conway, S.C. 29526 Ph. 843-248-5741, the
attorneys of record for Rev. Julian Lazar and wife Shirley, the Plaintiffs in this case. Ms.
Samples failed to answer or respond to the December, 2015 letter from the attorneys for Rev.
Julian Lazar and wife Shirley. The crutch of the case was that Julie M. Samples, a Licensed
Real Estate Agent, had failed to disclose pertinent and important information about the home
the Lazar were buying, and Ms. Samples was charged with, Negligence, Negligence
Misrepresentation, Fraud, Breach of Fiduciary Duty, and Failure to Disclose on a Residential
Property Condition Disclosure Statement.
One of the main possible witnesses for the Plaintiffs in this case was Sabrina Morris,
Director of the Planning and Zoning Department of the Town of Surfside Beach, who knew and
had full understanding of the laws concerning houses in the floodplain area for the Town of
Surfside Beach. Ms. Samples, husband during the time of the sale of the real estate which was
the subject of this lawsuit was former Mayor Douglas F. Samples, who had voted and passed all
laws regarding homes in the flood plains. Ms. Samples, in the sale of the real estate, knew or
should have known, of all the laws concerning the sale of property in a floodplain, as it was her
own husband who debated, voted on and had helped pass these laws.
COUNT ONE, DIRECT CONFLICT OF INTEREST:
During the election in the summer of 2016, Julie M. Samples, was heard by witnesses
saying that if elected that she would see to it that, Sabrina Morris, Director of Planning and
Zoning would lose her job and be fired and terminated . Subsequently, Ms. Samples as an
elected official, worked and conspired with the former Administrator to bring forward false,
unfounded and untruthful statements about, Sabrina Morris, Director of Planning and Zoning.
Ms. Samples reasons were if Sabrina Morris, Director of Planning and Zoning were fired if
would support Ms. Samples defense in the lawsuit against Julie M. Samples and possibly help
in the final financial outcome of the trial. Sabrina Morris, Director of Planning and Zoning was
eventually fired and Julie M. Samples, an elected official, supported the firing of Ms. Morris by
the Administrator, even though there was no cause to her firing, thus helping in the financial
outcome of the trial.
Julie M. Samples, used her position as an elected official, to bring about the firing and
termination of Sabrina Morris, Director of Planning and Zoning, and violate the ‘Rules of
Conduct’ in which it states: S.C. Code of Laws Section 8-13-700 (A) “A public official,
public member, or public employee may not knowingly use his official office, membership, or
employment to influence a government decision to obtain an economic interest for himself, a
family member, an individual with whom he is associated, or a business with which he is
associated.” .
Further in S.C. Code of Laws Section 8-13-700 (A) it states that ; “No public official,
public member, or public employee may make, participate in making, or in any way attempt to
use his office, membership, or employment to influence a governmental decision in which he, a
family member, an individual with whom he is associated, or a business with which he is
associated has an economic interest. A public official, public member, or public employee who,
in the discharge of his official responsibilities, is required to take an action or make a decision
which affects an economic interest of himself, a family member, an individual with whom he is
associated, or a business with which he is associated shall:
(1) prepare a written statement describing the matter requiring action or decisions and the
nature of his potential conflict of interest with respect to the action or decision;
(4) if he is a public official, other than a member of the General Assembly, he shall
furnish a copy of the statement to the presiding officer of the governing body of an agency,
commission, board, or of a county, municipality, or a political subdivision thereof, on which he
serves, who shall cause the statement to be printed in the minutes and require that the member
be excused from any votes, deliberations, and other actions on the matter on which the potential
conflict of interest exists and shall cause the disqualification and the reasons for it to be noted in
the minutes;
(5) if he is a public member, he shall furnish a copy to the presiding officer of an agency,
commission, board, or of a county, municipality, or a political subdivision thereof, on which he
serves, who shall cause the statement to be printed in the minutes and shall require that the
member be excused from any votes, deliberations, and other actions on the matter on which the
potential conflict of interest exists and shall cause such disqualification and the reasons for it to
be noted in the minutes.
During the time, when Julie M. Samples took office, till the day that Sabrina Morris,
Director of Planning and Zoning was fired and terminated. Julie M. Samples , never submitted
a verbal notice and or a written notice, to any public employee or any public official, or the
general public, or anyone that there was a ‘conflict of interest’, or that Ms. Samples was
embroiled in a pending lawsuit, where Sabrina Morris, Director of Planning and Zoning for the
Town of Surfside Beach was involved as a possible witness for the plaintiffs , and that there
was a definite and actual conflict of interest, for her to discuss, to not recuse herself, or to not
take herself out of any conversation or any reasons why she should be excused from any
conversation concerning the firing and or termination of Sabrina Morris, Director of Planning
and Zoning. Julie M. Samples therefore received a financial gain from the firing and
termination of Sabrina Morris, by discussing and supporting the firing and termination of
Sabrina Morris, as it would help Ms. Samples on the defense of her case, and the financial
outcome of the case against Ms. Samples. Because of Julie M. Samples, failure to recuse
herself, and her direct involvement in the firing and termination of Sabrina Morris, by
conspiring with the former Administrator, to bring about the firing and termination of Sabrina
Morris, the S.C. Ethics Commission, should fine, penalize or bring criminal charges against
Julie M. Samples.
 COUNT TWO , DIRECT CONFLICT OF INTEREST:

After Sabrina Morris, Director of Planning and Zoning, was wrongfully terminated from the
Town of Surfside Beach, a lawsuit was in the process of being filed against the Town of
Surfside Beach by Sabrina Morris for wrongful termination. The lawsuit against the Town of
Surfside Beach was a very strong lawsuit and it was said that the Attorney for Sabrina Morris
was ready to pursue the legal action to the fullest extent of the law against the Town of Surfside
Beach.

This legal matter against the Town of Surfside Beach was well known by most of the citizens
and staff of the Town of Surfside Beach. Also the case against Julie M. Samples, Case number
2016CP2605531, as a Defendant, along with the following other Defendants. Ie; James D
Keene III & Dianne L. Tinney, Re-Max Southern Shores (Samples’s employer), William G
Nichols III, Dunes Realty, Inc. dba Dunes Realty Sales , Gary A. Blake, Beyond Contracting,
Inc., The Town of Surfside Beach and Stewart Title Company aka Stewart Title Guaranty
Company was still an ongoing case, with possibly no end in sight during the fall of 2017 and
into January 2018.

The Town of Surfside Beach Attorney according to reliable sources had said that the case filed
by Sabrina Morris was an unwinnable case, in that the Plaintiff in that case had documented
several scenarios that would put the town at high risk of losing any legal battle in court.

On January, 23rd , 2018 , town council held a meeting in which the council made a motion to
reinstate Sabrina Morris, Director of Planning and Zoning. Below is a brief copy of the actual
meeting showing who was in attendance and who made the motions and who stated any
opposition and or voted for or against the ‘Reinstatement of Sabrina Morris’ (the actual minutes
are attached as evidence # )
1 SURFSIDE BEACH TOWN COUNCIL MEETING MINUTES
3 REGULAR MEETING JANUARY 23, 2018 6:30 P.M.
4 TOWN COUNCIL CHAMBERS
18 Town Council Meeting – 6:30 p.m.
20 1. CALL TO ORDER. Mayor Childs called the regular meeting to order at 6:30 p.m. Mayor Childs,
21 Mayor Pro Tempore Ott, and Councilmembers Courtney, Johnson, Pellegrino, Samples, and Stevens were in
22 attendance. A quorum was present. Others present: Administrator Fellner; Town Clerk Herrmann; Deputy
23 Administrator Harrah; Finance Director King; Fire Chief Otte; Police Chief Hofmann, and Public Works Director
24 John Adair
. Town Council Regular Meeting
. January 23, 201703

704 Reinstatement of former Planning, Building and Zoning Director Morris. Mr. Stevens moved to
705 reinstate Sabrina Morris as the Town of Surfside Beach director of planning, building and zoning effective
706 immediately. Mr. Courtney second. Ms. Samples said I just would like to say that the, just for the record, that the
707 labor attorney from Columbia strongly urged us not to do this, or some of this, and I just want that to go on the
708 record. Mayor Pro Tempore Ott, and Councilmembers Courtney, Johnson, and Stevens voted in favor. Mayor Childs
709 and Councilmembers Pellegrino and Samples voted against. MOTION CARRIED.
Page 13 of 26
As you can plainly see in the excerpts from the January 23rd, 2018 minutes shown above
and the actual minutes of the meeting (exhibit # ). The minutes show that Julie M. Samples,
was in attendance at the meeting as a ‘Public Official’ and was acting in an official capacity as
an ‘Elected Public Official’. As was stated earlier, Julie M. Samples, an elected Council
Member and Public Official was still involved in the middle of a pending lawsuit where, Ms.
Samples, as a defendant, had a financial involvement, and possible financial gain or loss, by
Sabrina Morris, former Director of Planning and Zoning testifying as a possible witness for the
plaintiffs, Rev. Julian Lazar and wife Shirley, represented by the Law Firm of Thompson &
Henry PA.
During the town council meeting there was a motion made to reinstate, Sabrina Morris as the
Director of the Planning and Zoning for the Town of Surfside Beach. This motion was made
and seconded, during the discussion , Julie M. Samples, made the following statement for the
record on lines 706. 707 and 708. “Ms. Samples said I just would like to say that the, just for
the record, that the labor attorney from Columbia strongly urged us not to do this, or some of
this, and I just want that to go on the record.”
Then on line 709 , Julie M. Samples, voted against Sabrina Morris being reinstated as
Director of Planning and Zoning, which Ms. Samples voted against the reinstatement, in
violation of ARTICLE 7, Rules of Conduct, SECTION 8 13 700. Use of official position or
office for financial gain; disclosure of potential conflict of interest. (A) No public official,
public member, or public employee may knowingly use his official office, membership, or
employment to obtain an economic interest for himself, a family member, an individual with
whom he is associated, or a business with which he is associated. This prohibition does not
extend to the incidental use of public materials, personnel, or equipment, subject to or available
for a public official’s, public member’s, or public employee’s use that does not result in
additional public expense.
And a further Violation of ARTICLE 7, Rules of Conduct, SECTION 8 13 700. B, 1, 4 &
5 which states (B) No public official, public member, or public employee may make,
participate in making, or in any way attempt to use his office, membership, or employment to
influence a governmental decision in which he, a family member, an individual with whom he
is associated, or a business with which he is associated has an economic interest. A public
official, public member, or public employee who, in the discharge of his official
responsibilities, is required to take an action or make a decision which affects an economic
interest of himself, a family member, an individual with whom he is associated, or a business
with which he is associated shall:
(1) prepare a written statement describing the matter requiring action or decisions and the
nature of his potential conflict of interest with respect to the action or decision;
(4) if he is a public official, other than a member of the General Assembly, he shall furnish
a copy of the statement to the presiding officer of the governing body of an agency,
commission, board, or of a county, municipality, or a political subdivision thereof, on which he
serves, who shall cause the statement to be printed in the minutes and require that the member
be excused from any votes, deliberations, and other actions on the matter on which the potential
conflict of interest exists and shall cause the disqualification and the reasons for it to be noted in
the minutes;
(5) if he is a public member, he shall furnish a copy to the presiding officer of an agency,
commission, board, or of a county, municipality, or a political subdivision thereof, on which he
serves, who shall cause the statement to be printed in the minutes and shall require that the
member be excused from any votes, deliberations, and other actions on the matter on which the
potential conflict of interest exists and shall cause such disqualification and the reasons for it to
be noted in the minutes.
Julie M. Samples, had a legal obligation, under the South Carolina Rules of Conduct and
the S.C. Code of Laws to withdraw herself completely from any votes and or consideration of
Sabrina Morris to be reinstated as the Planning and Zoning Director of the Town of Surfside
Beach. Ms. Samples failure to recuse herself and provide a written documentation of her
conflict of interest, and the fact Sabrina Morris would be called as a witness for the Plaintiffs in
Case number 2016CP2605531, and testify to facts that would affect the financial outcome of
Julie M. Samples case as one of the Defendants in this lawsuit, is a violation of the SC Ethics
Laws herein stated.