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 ComplaintBEFORE 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.govBEFORE 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 304.
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 0301. 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 30on
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 403010.
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 $0f3017.
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 03026.
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 7030SHERATON 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 3047.
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 9073058.
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 3068.
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 0f3019,
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 12.0f3089, 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 30GREEN 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 030110, 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 30campaign 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 30campaign 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 200130173. 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 30campaign 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