Tennessee eaf Etc 81 Campaign Finance Ethics Commission Sworn Complaint Tennessee Ethics Commission This form must be used to report alleged violations of any law within the jurisdiction of the Tennessee Ethics Commission. Please read the instructions before completing this form (failure to complete the form properly may result in dismissal of the complaint pursuant to T.C.A. INFORMATION 1. Complainant (First and Last Name): Chip Forrester Mailing Address: llO4Stonewall Jackson Court, Nashville, TN 37220-17% Telephone: E-mail (if available): (615) 4290840 chipforrester@hotmail.oom 2. Alleged Violators (First and Last Name of each List the position or title of each alleged violator alleged violator) Eill l-ladam Govemor of Tennessee Mailing address of each alleged violator: Oflioe of Governor Haslam Floor, State Capitol Nashville, TN 37243 STATEMENT OF I. Provide a short and plain statement of the nature of the violation(s). 1. El ll Haslam failed to disclose a campaign expenditure, the arvioes of political adviaorTom Ingram, which is required by state law. (see 2. List each law or rule (providing the specific citation) allegedly violated. 2-101% Each candidate for state public office and political campaign oommittee in a state election shall tile with the registry of election finance a statement of all contributions received and all expenditures made by or on behalf of such candidate or sudi committee. The statement of each candidate for state public offioe shalt indude the date of the receipt of each contribution, and the statement ofa political campaign committee in a state election shall ind ude the date ofeach expenditure that isa contribution to a candidate in any election. 55-8003 (May 2013) STATEMENT OF ACTS State all facts that constitute each alleged violation. State the dates upon which (or the time period within which) violation allegedly occurred. Attach additional sheets as needed, signing and numbering each page. See ATTACHMENT ONE ss-8003 (May 2013) SUPPORTING DOCUMENTATION 1. List all documents and other materials in your possession tl1at are relevant to this complaint. These documents should be attached to this complaint. "Did Govemor Hasiam Beak Campaign l-"lnanoe Laws?' NewsChannel5.oom, 7/1 1/13; "l-lasiam Defends Seoet Paymentsto Lobbyist' NewsChannel5.oom, 5/13/13; "I-laeiam Keeps Payments Private" New9Channei5.com, 5/lO/13 2. List all documents and other materials relevant to this complaint that are available to you, but are not currently in your possession. State the last known location of the document or material. 3. List all documents and other materials that are relevant to this complaint but are not available to you. State the last known location of the document or material. Email oorrespondenoe related to campaign or political matters from orto Govemor Eill I-laslam, his ofiioe and/or campaign staff to or from Tom Ingram or any of his affiliated staff members, state or campaignrelated email AFFIDAVIT By my signature below, I attest to the following: I understand that, pursuant to T.C.A. submitting a complaint containing false information. or submitting a complaint in reckless disregard of the truth or falsity of the information contained therein, constitutes a Class 2 offense which may subject me to civil penalties in an amount up to ten thousand dollars ($l0,000) and may additionally subject me to liability for the reasonable costs and attorney fees of the falsely accused; - The information contained in this complaint, and any supporting documentation or materials referenced herein or submitted herewith, is true and correct to the best of my knowledge. information and belief. Signature of Complainant Date Sworn to and subscribed before me this day of in County, Tennessee: Affix Notary Seal here Signature of Notary ss-8003 (May 20l3) Haslam Ethics Complaint ATTACHMENT ONE Statement of Facts From the beginning of 20} I through July 1st, 2013, Governor Bill Haslam failed to disclose expenses related to his gubernatorial campaign efforts, specifically the monies paid for the services of political adviser Tom Ingram. Haslam's campaign finance reports show that adviser Tom Ingram first appeared on his payroll in 2009, during Hasiam's gubernatorial campaign, and remained on his campaign's payroll through the end of 2010.' . However, since Haslam began his term as governor in early 2011, Haslam paid Ingram from a private account, which hides an expenditure that state law requires to be reported publicly, according to a News 5 report dated May 10, 2013.2 The governor's statements indicate that this relationship with and personal payment of Tom Ingram continued through the end oflune 2013. In an interview with News Channel 5 on May I3, 2013, Governor Haslam said, am paying him (Ingram) personally" for his "political advice." When the reporter asked Hasiam how much he paid Ingram, Haslarn declined to answer, saying, "That's personal. Like I said, I am paying him personally." Id. A Nashville City Paper article dated June 25, 2013, reported that Governor Haslam would begin to pay Torn Ingram through campaign funds rather than out of his own pocket." A News Channel 5 report states that I-Iaslam campaign officials confirm that campaignipayment of Tom Ingram began on July 2013.5 During this period of Governor Hasiam paying Tom Ingram from private accounts, not subject to disclosure rules that promote transparency and safeguard citizens, Tom Ingram played a role in managing the Governor's campaign events. In an article entitled "Did Governor I-Iaslam Break Campaign Finance Laws?" News Channel 5 reports that state emails "reveal Ingram participated in campaigmrelated planning events while he was on the governor's private payroll." "Early Year End Supplemental 2009." [Tennessee Registry of Election Finance, 7/14/10]. 2 "Hasiam Keeps Payments Private" lnewschannelS.com, 5/10/13] Accessed July 11, 2013. 3 "Haslam Defends Secret Payments to Lobbyist" [newschannei5, 5/13/13] Accessed July 11, 2013. 4 "Hasiam to put adviser Torn Ingram on campaign payroll." [nashviliecitypaper.com, 5 "Did Governor Haslam Break Campaign Finance Laws?" lnewschanne|5.com, 7/11/13} Ben Hail. I-laslarn Ethics Complaint 2 Though Governor I-Iaslam had previously said that Ingram "wasn't doing political work where it should be campaign [money to pay Tom Ingramj", the emails show that Tom Ingram attended a campaign retreat for Governor Haslam's 2014 reelection campaign. I In one particular e-mail, Governor Haslam's chief ofistaff Mark Cate asks Tom Ingram to set aside time for the eight--hour campaign event. In another e--mail, Tom Ingram suggests that the campaign host the campaign retreat at the Loews Vanderbilt Hotel because he preferred "to get away from government space." In another e-mail conversation between Tom Ingram and Governor Haslam's chief of staff in September 2012 with the subject line "planning session", Ingram told Cate that they "also needlied] to discuss super an apparently campaigmrelated subject. Hasiam Keeps Payments Private NewsChanne|S.com i Nashville News, weather 8: Sports 8/14/13 10:NC5 Investigates: Questions of influence Haslam Keeps Payments Private Posted: May 10, 2013 6:17 PM CDT Updated: May 10, 201.3 05:18 PM by Ben Hail Investigative Reporter NASHVILLE, Tenn. -- Governor Bill Hasiam is not revealing how much he personally pays lobbyist and consultant Tom Ingram. Newschannei 5 investigates first discovered that Governor Haslam has been paying Ingram out of his own pocked since 2011. Ingram offers political advice and consultation to other prominent politicians, but they pay him out of campaign funds and fully disclose all payments. Ingram lists on his website that he is a "consultant to Senators Alexander, Corker and Governor Hasiarn." He told Newschannei 5 Investigates there is nothing inappropriate about getting paid by public officials whom he also lobbies, because people are aware of his relationships. "As long as the relationship is known and out front, and we're careful about it, I think it's worked well for many years," Ingram said. Senators Bob Corker and Lamar Alexander make their relationship with Ingram known by reporting all payments to him on federal campaign disclosures. Alexander's campaign has paid Ingram $30,000 so far this year. Senator Cori