ARKANSAS ETHICS COMMISSION

910 WEST SECOND STREET, SUITE 100

LITTLE ROCK, AR 72201
Phone (501) 324-9600 Toll Free (800) 422-7773

CITIZEN COMPLAINT FORM

The undersigned person files this complaint and requests that the Arkansas Ethics Commission
conduct an investigation concerning the facts and actions detailed below for the purpose of determining
whether or not there has been a violation of laws under the Commissions jurisdiction.

1. Identify the person you are complaining about:

Name: Jason L. Brady
Address:

3018 Dapple Gray Road

Benton, AR 72015

Position or Title: Lobbyist/public official

Phone: (Home)
(Work) : 501-682-3835

2. State in your own words the detailed facts and the actions of the person named in section 1 which
prompted you to make this complaint. The brief space provided below is not intended to limit your
statement of facts. Please use the back of this form or additional sheets if necessary. Include relevant
dates, times, and the names, and addresses of other persons whom you believe have knowledge of the
facts.

Jason Brady in his capacity as a registered lobbyist for the American Cancer Societ Cancer Action
Network knowingly and willfully filed false lobbyist reports for the period July 2013 through
December 2014. He conspired with public servant Dennis Milligan to ensure his name and
activities on behalf of Mr. Milligan were not reported in campaign reports which, in-turn, would
have linked Mr. Brady to the false lobbyist reports he filed. Specifics and proof are attached.
3. Attach or make reference to any documents, materials, minutes, resolutions or other evidence which
support your allegations.

State of Arkansas
County of ____________________

I swear or affirm, under penalty of perjury, that

the facts set forth in this complaint are true and
correct to the best of my knowledge, information,
and belief.

Subscribed and sworn before me this

____ day of _____________, 20____.

Signature:
Print your name:

Notary Signature:

Mailing address:

My Commission Expires:

Phone:(Home)

Approved by the Arkansas Ethics Commission

(Work)

Revised 06/01

I allege American Cancer Society Cancer Action Network (hereafter ACS CAN) lobbyist reports
filed by Jason L. Brady purposely omitted, concealed, and falsified information required to be
included in his lobbyist activity reports covering the period July 2013 through December 2014.
Mr. Brady while employed by ACS CAN as their primary Arkansas lobbyist concurrently served
as campaign manager for Saline County Circuit Clerk Dennis Milligan, a public servant running
for Treasurer of State, for two elections. Mr. Brady performed campaign management duties
while an ACS CAN lobbyist, using his ACS CAN office, furnishings, computer and equipment,
telecommunications to include the telephone conference call system, and e-mail system. Mr.
Brady conspired with Mr. Milligan not to identify him in campaign filings, as required by law,
because his actions were in blatant violation of ACS CAN employee ethics rules. Exhibit 1 is
Mr. Bradys lobbyist registration for 2013 and 2014. Exhibit 2 is an extract from the ethics code.
Exhibit 3 is a March 11, 2014 email from Mr. Brady to campaign contractor Your Ad Team
(YAT) Shaun McFarland, and campaign treasurer Ulrich Rick Meyer directing a violation of
Arkansas campaign finance and contribution reporting law. In this email Mr. Brady said,
Shaun would you please include this bill for $308.96 in your next bill to the campaign for
reimbursement. After you receive a check from the campaign, would you mind reimbursing me?
Rick sorry to ask for this, but as you know, for my job security, I can NOT be listed
anywhere on a campaign contribution report.
Allegation 1. Mr. Bradys lobbyist reports did not provide a detailed statement of any money
loaned or line of credit established for this public servants campaign. Mr. Brady was
empowered with unquestioned campaign finance decision-making authority by Mr. Milligan in a
July 27, 2013 email to Mr. Meyer (exhibit 4). Mr. Brady purchased Facebook campaign
advertising on at least four occasions using his personal Facebook account #156971705 and
paying with his personal credit card. By Mr. Bradys direction, expenditures of $1,962.79 which
constituted money loaned or a line of credit for a public servant were reported in campaign
reports as being made by Mr. McFarland dba Your Ad Team (hereafter YAT). Mr. McFarland
reimbursed Mr. Brady with company checks obtainable by subpoena. When campaign emails
were made public in April 2015 and Mr. Brady was exposed, Mr. Milligan amended several
campaign reports to reflect Mr. Bradys purchases on their behalf. Subsequent September 18,
2015 amendments also listed Mr. Bradys campaign expenditures and reimbursements thereto.
a. Exhibit 5 is evidence of the first occurrence to conceal a $308.96 campaign expenditure and
reimbursement to Mr. Brady under the guise of a campaign expense incurred by YAT. The
campaign report for March 2014 (extract below) reports the campaign paid YAT with check
#1276. The amended campaign report for March 2014 filed on May 22, 2015 (exhibit 6)
reported the reimbursement to Mr. Brady who did not report this transaction in his March 2014
lobbyist report (exhibit 7).

3
Original campaign report entry:

Amended campaign report entries:

b. Another campaign expenditure made by Mr. Brady, invoiced, and reported as a YAT
expenditure occurred in April 2014 (exhibit 8). The original April 2014 campaign report lists a
$2,705.26 payment to YAT with check #1277 but the amended campaign report filed on May 22,
2015 (exhibit 9) lists a payment to Mr. Brady who did not report this transaction in his April
2014 lobbyist report (exhibit 10).
Original campaign report entry:

Amended campaign report entry:

c. There are several Facebook credit card purchases by Mr. Brady in May 2014 totaling
$402.26 shown in Exhibit 11. This expenditure was not reported in Mr. Bradys May 2014
lobbyist report (exhibit 10).
Allegation 2. Mr. Brady did not provide a statement or otherwise disclose his direct business
association with this public servant. That relationship is evidenced by exhibit 4 and the ACS
CAN investigate report summary at exhibit 12.
Rules on Lobbyist Registration and Reporting in 519 says, Pursuant to Ark. Code Ann. 7-6218(b)(4)(D), the Arkansas Ethics Commission may report any person found to have violated
any of these rules to the proper law enforcement authorities. In the interest of enforcing ethical
lobbyist behavior, we ask this be done following investigation confirmation of allegations.