STEPHEN

F. HUMPHREYS, PC
ATTORNEY AT LAW
P.O. Box 192
Athens, Georgia 30603
athenslaw@gmail.com
(706) 207 6982

The Honorable Nathan Deal

Office of the Governor
203 State Capitol
Atlanta, Georgia 30334
January 12, 2015
via fax 404 657 7332; email georgia.governor@gov.state.ga.us


Dear Governor Deal,

I am respectfully writing to follow up on my letter of October 31, 2014, in which I
called your attention to a pattern of ongoing criminal activity undermining the
University System of Georgia (USG) and Board of Regents, and requested you to
direct the Attorney General to investigate these matters, or else appoint a special
investigator pursuant to your authority under OCGA 45-15-18.

So far, I have received no response to that letter, and the Atlanta Journal-
Constitution has received no response from your office to its inquiries on the matter,
either. Attorney General Sam Olens, whose dereliction of his constitutional duty to
investigate and prosecute crimes prompted the request for the special appointment,
did respond to the newspapers inquiries, calling the well-documented allegations of
criminal fraud frivolous and nonsensical.

That response from the Attorney General only reinforces the need for a special
investigator, given that the criminal allegations so blithely dismissed by Mr. Olens
are completely documented by the USGs own records.

In fact, in the course of the civil RICO action related to the ouster of Anthony Tricoli
as president of Georgia Perimeter College, and in face of the extensive
documentation produced there, the Attorney General has admitted in court
pleadings that GPC budget reports were knowingly falsified by state officials, a
criminal offense under OCGA 16-10-20.

According to the USGs own public statements and self-audit, between $9.5 and
$18.5 million remain missing and unaccounted for in the aftermath of those
deliberate falsifications of GPC budget reports. These are the undisputed facts the

Attorney General dismisses as frivolous, and no independent investigation has ever

been conducted.

Since my last letter, the Attorney General has also admitted in court filings that the
USG made after-the-fact changes to its own policies--masking the violations that
occurred when GPC and USG officials made these knowing misrepresentations
regarding the GPC budget, as well as related matters that also fall under state
jurisdiction for purposes of OCGA 16-10-20, which makes any knowing
misrepresentation regarding state business a crime. In the case of Georgia
Perimeter College, the harm caused by the knowing misrepresentations was quite
evidentwith the loss of 300 jobs and an enrollment decline of 7000 students per
semester.

Despite the admission that these harmful criminal RICO predicate acts were, in fact,
committed, the DeKalb Superior Court entered an order on November 21, 2014
holding any state employees who allegedly stole money and covered it up by
falsifying state records immune under their financial oversight authority. If this
decision is a correct statement of the law in Georgia with respect to civil RICO
actionsthough we do not believe that it isthat only underscores the need for
criminal investigation and prosecution of the admitted violations of the Georgia
Criminal Code in this instance. We believe the Governor of Georgia should not wait
for a civil appeal to address these admitted crimes harming Georgias educational
institutions.

Similarly, in other pending cases, the Attorney General and USG freely admit they
have not investigated documented pension fraud based on illegally falsified leave
reports at the former Macon State College. The Attorney General and USG also admit
they have ignored documentation that former President Michael Adams and the
UGA Office of Legal Affairs oversaw a scheme to illegally impersonate UGA students,
sending out false correspondence and logging onto computer databases in the
students names, in order to fabricate false evidence that was knowingly used by the
Attorney General of Georgia in an attempted tenure revocation action--that failed
when this intentional fraud was proven in the legal proceedings.

Since this supporting documentation of the criminal activity in all these cases is
already in the Attorney Generals possession, the Attorney Generals own actions
and knowingly false statements dismissing the allegations deserve a full and
independent investigation. Since Attorney General Sam Olens clearly cannot manage
the conflict between defending state agencies in civil litigation and his duty to
prosecute state crimes, we do not see how the State of Georgia can afford to
continue to ignore this problem.

In our previous letter, we offered to supply you and your staff with the full
documentation supporting these criminal allegations. To that we can add the latest
admissions of criminal fraud, and look forward to your reply to this invitation to
review the relevant State records. It does fall to your authority under OCGA 45-

15-18 since the Attorney General has stated very plainly and publicly that he has not
and does not intend to investigate these matters.

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