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James D, Kreyenbubl Darryl A, Hicks Chair ‘Member Robert A. Watts David J. Burge Vice Chair ‘Member Rick Thompson David Emadi Member Executive Director Georgia Government Transparency and Campaign Finance Commission 200 Piedmont Avenue SE | Suite 1416 ~ West Tower | Atlanta, Georgia 30334 Phone (404) 463-1980 | Facsimile (404) 463-1988 www.ethics.ga.g0v May 15,2023 VIA FedEx Carl Gilliard 157 Enclave Blvd. Savannah, Ga. 31419 RE: IN THE MATTER OF CARL GILLIARD CASE NO, 22-0173-C Dear Mr. Gilliard: Enclosed you will find a copy of an amended complaint filed by the Georgia Government ‘Transparency and Campaign Finance Commission on May 15, 2023, which alleges that you violated the Georgia Government Transparency and Campaign Finance Act (hereinafter, “Act”). You have fourteen days to respond to the above-referenced amended complaint, in writing, if you should choose to do so. 5 of the Georgia pursuant to the Open You will be notified in advance of the time and place of any hearing. All m Government Transparency and Campaign Finance Commission are open to the publi Meetings Act. If you have any questions about procedure or other matters, please contact me at sknittel@ethies.ga.gov or 404-463-1980. Respectflly, Ste. Steven C. Ki Senior Staff Attorney SK:ke Enclosure: Amended Complaint BEFORE THE GEORGIA GOVERNMENT TRANSPARENCY AND. CAMPAIGN FINANCE COMMISSION STATE OF GEORGIA IN THE MATTER OF: * CASE NO: 22-0173-C CARL GILLIARD * CERTIFICATE OF SERVICE This will certify that I have, this day, delivered and served a true and exact copy of the foregoing Notice of Amended Complaint upon the following by placing a true and exact copy of same in the United State mail with adequate postage affixed thereto and addressed as follows: Carl Gilliard 157 Enclave Blvd Savannah, Ga. 31419 This 15" day of May 2023. MeO Ki terwood Senior Litigation Paralegal Georgia Government Transparency and ‘Campaign Finance Commission 200 Piedmont Ave, SE Suite 1416 — West Tower Atlanta, GA 30334 (404) 463-1980 (404) 463-1988 facsimile keasterwood@ethics.ga.gov BEFORE THE GEORGIA GOVERNMENT TRANSPARENCY ANI CAMPAIGN FINANCE COMMISSION STATE OF GEORGIA IN THE MATTER OF: CARL GILLIARD .D COMPLAL COMES NOW, the Georgia Government Transparency and Campaign Finance Commission (hereinafter Commission”) and files this Amended Complaint (hereinafter “Complaint”) against Carl Gilliard (hereinafier “Respondent”) and asserts the following: 1 The Respondent is a resident of Chatham County, State of Georgia, 2. Respondent was a candidate for election to the Georgia General Assembly in the 2022 election cycle and has served in the General Assembly since his election in 2016, and therefore, is subject to the jurisdiction and venue of this Commission, See O.C.G.A. § 21-5-2 (The Commission is charged with the enforcement of the Georgia Government ‘Transparency and Campaign Finance Act (hereinafter “Act”) in order to protect the integrity of the democr: process and hold public officers accountable). 3. Respondent may be served according to law at his address listed with the Commissi wit: 157 Enclave Blvd., Savannah, GA 31419, ‘Amended Complaint Inthe Matte of Cal Gilind ase No; 22-0173 Page 1 of 30 4. On March 4, 2016, Respondent filed his declaration of intention to accept campaign contributions for his campaign for election to the Georgia General Assembly. As the Respondent was seeking a position with a two-year term of office, the Act requires that any action alleging a violation of its terms must be commenced within three years from the date of filing of the first report containing said violation. O.C.G.A. § 21-5-13.' In the case sub judice, a sua sponte complaint was instituted by the Commission on December 20, 2022. As such, this complaint is not barred by the three-year statute of limitations pursuant to 0.C.G.A. § 21-5-13. 5. On or about March 8, 2022, Respondent qualified to stand for re-election to the Georgia General Assembly. 6 The General Assembly enacted a requirement that requires public officials and candidates for public office regularly and fully disclose the amount and sources of their campaign and expenditures, To that end, the Georgia General Assembly also instituted a very specific filing regimen that requites public officials and candidates for public office to regularly report their campaign contributions and campaign expenditures to the Commission and general public. See generally O.C.G.A.§ 21-5-34, 7. Respondent failed to file his Campaign Contribution Disclosure Reports within the applicable filing periods as contained in O.C.G.A. §§ 21-5-34(c)(2)(A) and (¢)(1)(A); to wit: " The Campaign Finance Act defines the commencement of an action for purpose of tolling the relevant statute of limitations as (1) the acceptance of a compliant pursuant to Code Section 21-5-7; or (2) the service of a summons or hearing notice by the Commission and/or the Attomey General notifying such person ofthe alleged violation ofthe ‘Campaign Finance Actin accordance with O.C.G.A. § 50-131, et seg Amended Complaint tn the Matter of Ce Giliard (Case Na: 22-0173 Page 2 030 1. Respondent failed to file his September 30, 2022 Campaign Contribution Disclosure Report in violation of O.C.G.A. § 21-5-34(c)(2). See Exhibit “A”. 2. Respondent failed to file his October 25, 2022 Campaign Contribution Disclosure Report in violation of 0.C.G.A. § 21-5-34(c)(2). See Exhibit “A”. 3. Respondent failed to file his June 30, 2020 Campaign Contribution Disclosure Report in violation of O.C.G.A. § 21-5-34(c)(2). See Exhibit “B” 4, Respondent failed to file his September 30, 2020 Campaign Contribution Disclosure Report in violation of 0.C.G.A. § 21-5-34(c)(2). See Exhibit “B” 8. ‘The General Assembly enacted a requirement that requires public officials and candidates for public office to disclose their personal financial holdings, through a personal financial disclosure statement (hereinafier “PFDS”), on a yearly basis so that the electorate will have the opportunity to identify potential self-dealing in the official’s/candidate’s public acts. See generally, O.C.G.A. § 21-5-50. 9 Respondent failed to file his PFDS in the applicable time periods as stated in O.C.G.A. § 21-5-50, to wit; A) Respondent failed to file his calendar year 2021 PFDS in violation of O.C.G.A. § 21-5-50, B) Respondent failed to file his calendar year 2020 PEDS in violation of OCGA. § 21-5-50. 10. The Georgia General Assembly promulgated the Campaign Finance Act in order to ensure that public officials and candidates for public office regularly and fully disclose the amount and sources of their campaign contributions and expenditures. To that end, the Georgia General Assembly also instituted a very specific filing regimen that requires public officials and candidates for public office to regularly report their campaign contributions and campaign expenditures to the Commission and general public. See generally O.C.G.A. § 21-5-34. Amended Complain Jn the Mater of Cz Gilliard Case No. 2-0173-C Page 3 of 30 on Pursuant to the Campaign Finance Act, contributions to a candidate or campaign committee and any proceeds from investing such contributions shall be utilized only to defray ordinary and necessary expenses incurred in connection with such candidate's campaign for lective office or such public officer’s fulfillment or retention of such office. O.C.G.A. § 21- 33(a). 12. mns and the interest thereon, shall not constitute the Additionally, campaign contrib personal assets of a candidate or public officer. Id. 13. In this matter, it is alleged that the Respondent improperly utilized approximately $55,316.01 in campaign contributions which were not used to defray ordinary and necessary ¢ spanning from January 3, expenses incurred in connection with the campaign for elective offi 2022 to the present as detailed infra: 1. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $87.14 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, OLIVE GARDEN on 01/03/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Exhibits “C” and “D”, 2. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $184.43 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, ON TIME FASHION on 01/06/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 3. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $36.69 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, JAMES PAIGE TUCKER on 01/12/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 4. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $50.46 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SHERATON ATLANTA FB on 01/12/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id Amended Complaint Inthe Mater of Cal Gilind Case No 22.017 Page 4030 10. 12. 13. 14, 15. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $54.12 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, HSUS GOURMET on 01/12/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id, Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $959.17 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, TITLEMAX on 01/12/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report, See Id. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $334.12 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, GEORGIA GIFTS AND MORE on 01/13/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $86.92 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SHERATON on 01/14/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $396.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SHERATON on 01/14/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. |. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $396.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SHERATON on 01/14/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. - Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $22.32 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, 244 CAFE on 01/25/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $48,02 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, D AND K SUIT CITY ATLANTA on 01/25/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $293.98 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, K & G ATLANTA on 01/25/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $196.49 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CUTS STEAKHOUSE on 01/26/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $16.73 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, In the Matter of Cal Gilied (Case No: 22-0173-C Page $0f30 17. 18. 20. 21. 22, 23. 24. 2s. . Respondent violated 0.C.G.A. § 21 SHERATON on 01/28/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. -33(a) when he expended $451.46 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SHERATON on 01/28/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $482.92 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SHERATON on 01/28/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $66.40 of campaign: funds to pay for an expense that was not a necessary and ordinary campaign expense, K & G ATLANTA on 01/31/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $19.59 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CM CHICKEN KOREAN STYLE on 02/01/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $14.15 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, GA TECH CHINESE TAURANT on 02/02/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $930.37 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, KENLEY’S CATERING on 02/03/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $396.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SHERATON on 02/07/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $396.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SHERATON on 02/07/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $115.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, ALPS EVIDENCE AND PHOTO on 02/10/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id, Respondent violated O.C.G.A. § 21-5-33(a) when he expended $115.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, ALPS EVIDENCE AND PHOTO on 02/10/2022 and failed to disclose this ‘expenditure on a Campaign Contribution Disclosure Report. See Id. Amended Complaint In he Mater of Ca Gilad (Case No: 2-O173-C Page 6 030 26. 21. 28. 29. 30, 31 33, 34, 35, 36. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $297.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SHERATON on 02/11/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $319.51 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SHERATON on 02/11/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $40.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CHECKING W/D on 02/18/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $297.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SHERATON on 02/18/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report, See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $347.45 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SHERATON on 02/18/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $241.46 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SHERATON on 02/25/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. . Respondent violated O.C.G.A. § 21-5-33(a) when he expended $320.88 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SHERATON on 02/25/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. . Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $15.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, NEWSPAPER SUBSCRIPTION on 03/10/2022 and failed to disclose this, expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $15.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, NEWSPAPER SUBSCRIPTION on 03/10/2022 and failed to disclose this, expenditure on a Campaign Contribution Disclosure Report. See Id, Respondent violated O.C.G.A. § 21-5-33(a) when he expended $50.53 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expen: SHERATON on 03/14/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $396.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, ‘Amended Complain tn the Mater of Ct Gillard (Case No: 22-0173-C Page 7030 SHERATON on 03/14/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 37. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $396.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SHERATON on 03/14/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 38, Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $8.76 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, AMC on 04/08/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 39. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $1,000.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CHECKING W/D on 04/1 1/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 40. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $300.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CHECKING W/D on 04/14/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 41. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $1,000.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CHECKING W/D on 04/22/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 42. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $176.67 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, BABES SMOKEHOUSE on 04/26/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 43. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $474.96 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, ‘TOP CRAB RESTAURANT on 04/26/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 44, Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $3,070.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, THE LILY MAR on 04/28/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 45, Respondent violated O.C.G.A. § 21-5-33(a) when he expended $600.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CHECKING W/D on 05/02/2022 and failed to disclose this expenditure on a ‘Campaign Contribution Disclosure Report. See Id. 46. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $1,000.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CHECKING W/D on 05/02/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id, ‘Amended Complaint Inthe Mater of Ca Gland Case No: 22.0173. Page 8 of 30 47. 48. 49. 50. 51. 52. 53. 54, 5s, 56. 37. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $26.35 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, QUICK STOP on 05/03/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $2,000.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, RUN THE WORLD SALE on 05/06/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $1,000.00 of campaign funds to pay for an expense that was not a necessary and ordinary ‘campaign expense, CHECKING W/D on 05/16/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $1,000.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CHECKING W/D on 05/16/2022 and failed to disclose this expenditure on Campaign Contribution Disclosure Report. See Id Respondent violated O.C.G.A. § 21-5-33(a) when he expended $1,000.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CHECKING W/D on 05/16/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $1,000.00 of ‘campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CHECKING W/D on 05/19/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $1,211.22 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, COURTYARD BY MARRIOTT SAVANNAH on 05/20/2022, and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $9.93 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, ZAXBY’S on 05/24/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id, Respondent violated O.C.G.A. § 21-5-33(a) when he expended $451.43 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CAREY HILLIARD on 05/24/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id, Respondent violated O.C.G.A. § 21-5-33(a) when he expended $227.98 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, THE DRAFT on 05/25/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $502.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, ‘Amended Complain Inthe Mater of Cu Gillis Case No- 22.0173 Page 90730 58. 59, 60. 61 62. 63. 65. 66. 67. KROGER on 05/31/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $1,000.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CHECKING W/D on 05/31/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $2,110.65 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SAVANNAH TOYOTA on 05/31/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $359.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, KROGER on 06/13/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $526.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, KROGER on 06/13/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $751.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, KROGER on 06/13/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $500.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, PAYPAL * ATLANTAB on 06/16/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $200.00 of camy funds to pay for an expense that was not a necessary and ordinary campaign expense, CHECKING WID on 06/16/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $55.14 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, BERWICK ACE HARDWARE on 06/21/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $68.78 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, 2 CHEFS GULLAH on 06/21/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $586.97 of camps funds to pay for an expense that was not a necessary and ordinary campaign expense, STUDIO 13 DESIGN on 06/21/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. “Amended Complaint Inthe Mater of Cr Giliars (Case No: 2.01730 Page 10 of 30 68. 69. 70, n 72, 73. 74, 15. 16. 71. 7B. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $113.29 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, BABES SMOKEHOUSE on 06/27/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $143.59 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, BABES SMOKEHOUSE on 06/27/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id, Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $249.96 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SAVANNAH TOYOTA on 07/01/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $78.51 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, HOME DEPOT on 07/05/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $354.35 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, HOME DEPOT on 07/05/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $1,000.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CHECKING W/D on 07/05/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $1,000.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CHECKING W/D on 07/05/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $506.58 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SAM’S CLUB on 07/12/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $188.10 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CRAB HOUSE on 07/18/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $1,300.00 of ‘campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CHECKING WITHDRAWAL on 07/18/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $445.25 of camps funds to pay for an expense that was not a necessary and ordinary campaign expense, ‘Amended Complain. In the Matter of Ca iliard (Case No: 22.0173.0 Page 11 0f30 19, 80. 81 82. 83. 84, 86, 87. 88, . Respondent violated 0.C.G.A. § 21- ON TIME FASHION on 07/25/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $590.60 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, STUDIO 13 DESIGN WEAR on 07/25/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $258.88 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, LASER LIGHT ENGR on 07/26/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. - Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $260.80 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CAREY HILLIARD on 07/27/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $61.52 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, B. MATTHEWS on 07/28/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $29.89 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, BERWICK ACE HARDWARE on 07/29/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $67.96 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, KROGER on 07/29/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. . Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $415.16 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, PARTY CITY on 08/01/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $3,409.75 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, BARNES RESTAURANT on 08/01/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $110.93 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CAREY HILLIARD on 08/02/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 33(a) when he expended $233.74 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, BEST WESTERN HOTEL on 08/02/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. Amended Complain In the Mater of Cat Gili (Case No: 22-0173.0 Page 12.0f30 89, Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $47.03 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CLARYS CAFE-ABER on 08/15/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 90, Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $65.23 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, IT’S A JERK SHACK on 08/15/2022 and failed to disclose this expenditure on a ‘Campaign Contribution Disclosure Report. See Id, 91. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $65.23 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, RHETT AT THE ALI on 08/15/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 92. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $123.32 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SAVAHHAH RIVERBOAT on 08/15/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 93, Respondent violated O.C.G.A. § 21-5-33(a) when he expended $324.66 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, JW MARRIOTT on 08/15/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id 94. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $270.08 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, ELIZABETH ON 37'"' on 08/16/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id 95. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $127.80 of camps funds to pay for an expense that was not a necessary and ordinary campaign expense, ON TIME FASHION on 08/22/2022 and failed to disclose this expenditure on a ‘Campaign Contribution Disclosure Report. See Id 96. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $33.41 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, BERWICK ACE HARDWARE on 08/29/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 97. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $60.41 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, GENEVA’S FAMOUS on 08/29/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 98. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $48.11 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, BABES SMOKEHOUSE on 08/30/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 99. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $56.66 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, “Amended Compeint, Inthe Mater of Cae Gilliard (Case No: 22-0173 Page 13 of 30 GREEN TEA on 08/30/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 100. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $106.96 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, DTLR 094 GARDEN CITY on 08/30/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 101. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $170.00 of campaign funds to pay for an expense that was not a necessary and ordinary ‘campaign expense, POOLER DAY SPA on 09/02/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 102. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $51.04 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, HOBBY LOBBY on 09/06/2022 and failed to disclose this, expenditure on a Campaign Contribution Disclosure Report. See Id. 103. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $63.66 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SAKURA on 09/06/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 104, Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $101.62 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, PETSMART on 09/06/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 105, Respondent violated O.C.G.A. § 21-5-33(a) when he expended $130.31 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, BIG LOTS STORES on 09/06/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 106. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $261.06 of ‘campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, STAPLES on 09/06/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 107. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $55.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, STEAMLINE DRY CLEANER on 09/02/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 108. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $128.40 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, PAYPAL * AHHAIRL on 09/20/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 109. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $16.86 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, T-MOBILE on 09/22/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report, See Id. ‘Amended Complaint In the Matter of Cart Giliaed Case No: 2-017. Page 1 030 110, Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $259.24 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, K & G ATLANTA on 09/23/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id, 111, Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $30.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, GA0104 SAVANNAH on 09/26/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 112, Respondent violated O.C.G.A. § 21-5-33(a) when he expended $60.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, GA0104 SAVANNAH on 09/26/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 113. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $67.89 of, campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, RIVERSIDE STORE on 09/26/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 114, Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $87.25 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, OMNI HOTELS on 09/26/2022 and failed to disclose this, expenditure on a Campaign Contribution Disclosure Report. See Id. 115. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $97.37 of, campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, ROSIE’S CAFE on 09/26/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 116, Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $150.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CHECKING W/D on 09/26/2022 and failed to disclose this, expenditure on a Campaign Contribution Disclosure Report. See Id. 117. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $529.92 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, DAVID'S CRAB on 09/26/2022 and failed to disclose this, expenditure on a Campaign Contribution Disclosure Report. See Id. 118. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $168.56 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SHERATON on 09/27/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 119, Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $168.56 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SHERATON on 09/27/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 120. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $21.00 of campaign funds to pay for an expense that was not a necessary and ordinary ‘Amended Complain In the Mater of Ca Ciird (Case No; 22-0173-C Page 15 0 30 campaign expense, LEE NAILS VICTOR on 10/03/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id, 121. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $76.76 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, KROGER on 10/03/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 122. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $103.36 of ‘campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, PAPAS BAR B QUE on 10/03/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id 123, Respondent violated O.C.G.A. § 21-5-33(a) when he expended $115.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, RACK ROOM SHOES on 10/03/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report, See Id. 124, Respondent violated O.C.G.A. § 21-5-33(a) when he expended $117.95 of campaign funds to pay for an expense that was not a necessary and o campaign expense, ISLAND BREEZE on 10/03/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 125. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $131.90 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, HERB CREEK LANDS on 10/03/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 126. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $500.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CREATIVE COMPANY on 10/03/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id 127, Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $22.22 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, MCDONALD'S on 10/05/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report, See Id. 128. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $83.54 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SUNNY SIDE UP on 10/06/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 129. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $13.38 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SAVANNAH FILIPIN on 10/03/2022 and failed to disclose this, expenditure on a Campaign Contribution Disclosure Report. See Id. 130. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $30.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, GAO104 SAVANNAH on 10/11/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id ‘Amended Complint Inthe Mater of Car Gilliard Case No: 2201736 Page 16.030, 131. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $137.92 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, ON TIME FASHION on 10/11/2022 and failed to disclose this expenditure on Campaign Contribution Disclosure Report. See Id. 132. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $207.49 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, LOWE'S on 10/11/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 133. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $245.00 of campaign funds to pay for an expense that was not a necessary and o: campaign expense, CELL TOUCH on 10/1 1/2022 and failed to discl expenditure on a Campaign Contribution Disclosure Report. See Id. 134, Respondent violated O.C.G.A. § 21-5-33(a) when he expended $376.53 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, EYE GLASS WORLD on 10/11/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 135. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $20.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, 8253 SV GULF COA on 10/13/2022 and failed to disclose this, expenditure on a Campaign Contribution Disclosure Report. See Id. 136. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $30.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, GA0104 SAVANNAH on 10/14/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 137. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $6.42 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, QUIKYS FAMOUS on 10/17/2022 and failed to disclose this expenditure on a Campaign Conttibution Disclosure Report. See Id. 138. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $7.22 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, STARBUCKS on 10/17/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 139, Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $7.22 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, STARBUCKS on 10/17/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id 140. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $13.59 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, STARBUCKS on 10/17/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 141. Respondent violated O.C.G.A. § 21-3-33(a) when he expended $18.19 of campaign funds to pay for an expense that was not a necessary and ordinary ‘Amended Complaint lhe Mater of Cet Giliaed (Case No; 22-0173-C Page 17 0630 ‘campaign expense, PANDA EXPRESS on 10/17/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 142. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $25.65 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, BERWICK ACE HARDWARE on 10/17/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 143. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $31.01 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, EL. MARIACHI RESTAURANT on 10/17/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 144, Respondent violated O.C.G.A. § 21-5-33(a) when he expended $31.03 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, BAKERS PRIDE on 10/17/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 145. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $78.73 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CHINATOWN BUFFET on 10/17/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 146. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $11.75 of campaign funds to pay for an expense that was not a necessary and ordinary ‘campaign expense, BEAUTY MECCA on 10/24/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 147, Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $55.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, REECE BARBEC on 10/24/2022 and failed to disclose expenditure on a Campaign Contribution Disclosure Report. See Id. 148. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $234.54 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, MIY ABI KYOTO STEAHOUSE on 10/24/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 149. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $30.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, GA0104 SAVANNAH on 10/26/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 150. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $272.85 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, LASER LIGHT ENGR on 10/26/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 151. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $120.98 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CAREY HILLIARD on 10/31/2022 and failed to disclose this, expenditure on a Campaign Contribution Disclosure Report. See Id Amended Complaint Inthe Matter of Ca Gilliard (Case No: 22-0173. Page 18 030, 152, Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $46.45 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, BABES SMOKEHOUSE on 11/01/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 153. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $55.61 of campaign funds to pay for an expense that was not a necessary and ordinary ‘campaign expense, IT’S A JERK SHAC on 11/02/2022 and failed to disclose this, expenditure on a Campaign Contribution Disclosure Report. See Id. 154, Respondent violated O.C.G.A. § 21-5-33(a) when he expended $30.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, GA0104 SAVANNAH on | 1/08/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id, 155. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $30.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, GA0104 SAVANNAH on 11/14/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id, 156. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $220.57 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, DIASPORA MARKET on 11/14/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report, See Id. 157. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $45.45 of ‘campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CLARYS CAFE-ABER on 11/15/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 158. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $593.25 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, ON TIME FASHION on 11/15/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 159. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $2.13 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CHOPSTICKS CHINE on 11/16/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 160. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $55.64 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, CRAB HOUSE on 11/18/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id 161. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $583.15 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, LASER LIGHT ENGR on 11/18/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 162. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $26.96 of campaign funds to pay for an expense that was not a necessary and ordinary Amended Complaint In the Mater of Car Ciling (Case No; 22-0173 Page 19 of 30 campaign expense, PUBLIX SUPERMARKET on 11/21/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 163. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $70.41 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, WAL-MART SUPER on 11/21/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 164, Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $116.64 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SAVANNAH PRIME on 11/21/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report, See Id. 165. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $16.47 of campaign funds to pay for an expense that was not a necessary and ordinary ‘campaign expense, ROAD TRIP MACON on 11/22/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id 166. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $350.61 of campaign funds to pay for an expense that was not a necessary and ot campaign expense, BEST WESTERN HOTEL on 11/22/2022 and fai this expenditure on a Campaign Contribution Disclosure Report. See Id. 167. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $8.69 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, JJ FISH 7 CHICKEN on 11/25/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 168. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $26.72 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, JJ FISH 7 CHICKEN on 11/25/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 169. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $30.00 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, GA0104 SAVANNAH on 11/28/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 170. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $150.00 of campaign funds to pay for an expense that was not a necessary and ordinary ‘campaign expense, POOLER DAY SPA on 11/28/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 171, Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $7.22 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, STARBUCKS on 11/29/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id 172. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $16.12 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, 5 GUYS on 11/29/2022 and failed to di a Campaign Contribution Disclosure Report, See Id. lose this expenditure on Amended Complaint In the Mater of Car Gilid (Case No: 22-0173.0 Page 200130 173. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $335.92 of ‘campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, ON TIME FASHION on 11/29/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 174, — Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $21.67 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, STARBUCKS on 11/30/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report, See Id. 175. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $31.75 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, STEAMLINE DRY CLEANERS on 11/30/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id, 176. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $7.04 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SPRINT FOOD on 12/05/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 177. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $86.47 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, EGGS UP GRILL on 12/05/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 178. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $30.00 of ‘campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, GA0104 SAVANNAH on 12/08/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id 179. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $19.78 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, LA CHALUPA on 12/09/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 180. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $21.40 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, QUIKYS FAMOUS on 12/12/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 181. Respondent violated 0.C.G.A. § 21-3-33(a) when he expended $23.52 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, BL MARIACHI RESTAURANT on 12/12/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id 182. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $118.25 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, THE PIRATES HOUSE on 12/12/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 183. Respondent violated O.C.G.A. § 21-5-33(a) when he expended $181.10 of campaign funds to pay for an expense that was not a necessary and ordinary Amended Complaint Inthe Mater of Cet Grd Case No: 22.0173.6 Page 21 of 30 campaign expense, CRAB HOUSE on 12/12/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 184, Respondent violated O.C.G.A. § 21-5-33(a) when he expended $261.54 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, THE PIRATES HOUSE on 12/12/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 185, Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $44.38 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, MARCOS PIZZA on 12/13/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 186. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $30.00 of ‘campaign funds to pay for an expense that was not a necessary and ordinary ‘campaign expense, GAO104 SAVANNAH on 12/14/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 187, Respondent violated O.C.G.A. § 21-5-33(a) when he expended $7.22 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, STARBUCKS on 12/15/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 188. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $2.68 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SAMS CLUB on 12/19/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report, See Id. 189. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $44.35 of ‘campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, ALDI on 12/19/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 190, Respondent violated O.C.G.A. § 21-5-33(a) when he expended $188.88 of campaign funds to pay for an expense that was not a necessary and ordinary ‘campaign expense, WAL-MART on 12/19/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id 191, Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $199.01 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, SAMS CLUB on 12/19/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id. 192. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $286.14 of campaign funds to pay for an expense that was not a necessary and ordinary campaign expense, ON TIME FASHION on 12/20/2022 and failed to disclose this, expenditure on a Campaign Contribution Disclosure Report. See Id. 193. Respondent violated 0.C.G.A. § 21-5-33(a) when he expended $299.37 of campaign funds to pay for an expense that was not a necessary and ordinary ‘campaign expense, K & G ATLANTA on 12/21/2022 and failed to disclose this expenditure on a Campaign Contribution Disclosure Report. See Id “Amended Complaint ln the Matter of Cart Giliard (Case No: 2.01730 Page 22.030

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