SWORN COMPLAINT BEFORE THE TEXAS ETHICS COMMISSION ‘An individual must be a resident of the state of Texas to be eligible to file a sworn complaint with the Texas Ethics Commission. The complainantis required to attach to the complaint a copy of one of the following documents: + complainant's driver's license or personal identification certficate issued under Chapter $21 Of the Transportation Code. of commercial driver's hoense issued under Chapter $22 of the Transportation Code. or + a.ubity bil bank statement. govemment check. paycheck or other government document that Shows the name and address of the complainant and is dated not more than 30 days before the date on which the complaint is fled, {An individual may also be eligible to fle a sworn complaint with the Texas Ethics Commission # the individual owns real property in the state of Texas. Under tis provison. the complanant willbe required tach to the complaint a copy of a property tax ill notice of appraised value. of other government document that shows the name of the complainant, shows the address of he real property m Texas, and Identifies the complainant asthe owner of the eal property Please completely fill out this form. Failure to complete this form properly will ‘cause your complaint to be noncompliant and rejected. OFFICE USE ONLY OPY. HAND DELIVERED RECEIVED APR 12 2016 Texas 1, IDENTITY OF COMPLAINANT 1 COMPLAINANT 5 NAME Lucy v Stein Austin compuanant [ PHYSICAL PoE '500 San Marcos St 110 thane oy einem aren tcedng ste By ste are 988) 3 COMPLAINANT MAILING ADDRESS. [Xeon 3 COMPLAINANT = 4 COMPLAINANT TELEPHONE E-MAIL NUMBER 512.473.4140 ADDRESS. IDENTITY OF RESPONDENT 6 RESPONDENT 7 NAME Lucy@ProgressTexas.1g carol! sianey 7 RESPONDENT POSITION OR TITLE [a RESPONDENT PHYSICAL ADDRESS |e RESPONDENT MAILING ADDRESS: x Sid _ Agreulture Commissioner 6407 S US Hwy 377 1x Stephenvite 0 RESPONDENT > ca RESPONDENT TELEPHONE E-MAILADDRESS RUMEES ee IREQURED # KNOWN GO TO PAGE 2 by Texas Eines Commission wan abies Hae Revacs 112lll. NATURE OF ALLEGED VIOLATION Page2 Include the specific law(s) or rule(s) alleged to have been violated. The Texas Ethics Commission has jurisdiction to enforce only the following laws: (1) Tite 15 of the Election Code; (2) Chapters 302, 303, 305, 572, 2004 of the Gov'tCode; (3) § 334.025 and § 335,055 of the Local Gov't Code; (4) Subchapter C. Chapter 159 of the Local Gov't Code, in connection with a county judicial officer who elects to filea financial statement with the commission: (5) § 212.064 and § 2185.003 of the Govt Code; (6) § 306.005 of the Gov't Code. Please completely fil out this form. Failure to complete this form propery will cause your complaint to be nocompliant and rejected. | respectully request thal the Texas Ethics Commission investigale whether Agriculture Commissioner Sid Miler viclate: 1. Title 15 ofthe Election Code, Section 253.035 (a) by converting campaign contibutions for personal use. ‘According Wo a press report published in tye Houston Chronicle on Apxil 8, 2016, Se Miler spent “nearly $2,000 in siale and campaign ‘cash on [a three-day rip o Jackson, Miss..n February 2015. Rilerlalerused campaign funds to reimburse the state for the portion of trip paid for with stale funds. Utimately, the fll kip was paid for using campaign funds, ‘The purpose of this rip 1 Jackson was primarily personal in nature, Mill's spokesperson told the paper Tit was a personal tip so hhe could compete in a rodeo." During the competition hiller won $880. 2. Tile 15 of the Election Code, Section 254.031 (a) by faling lo report two poltical expenditures ‘According to the same reporlin the Houston Chronele, Miller di not report two expenditures paid tothe stale to cover other costs ‘associated with tes trp ATTACH ADDITIONAL PAGES AS NEEDED. ons provided by Texas Eihics Commission ‘wow ethics lalate Reveed 10122015IV. STATEMENT OF FACTS Page3 9 the sites violation(s), including the dates on which or the period of State the facts constitu time in which the alleged vi the complainant, but alleged on int statements. Please completely fill out this form. Failure to complete this form properly will cause your complaint fo be noncompliant and rejected. ee iolation(s) occurred. Identify allegations of fact not personally known to formation and belief. Please use simple, concise, and direct 1. Milor used at least $1,814 n campaign contibutions for his personal use: The Houston Chronicle reporter Brian Rosenthal discovered ‘hat Miller used “a campaign account card fora hotel room and a rental caro charge $793, Rosenthal also found while Miler originally paid for $1,021 in airfare costs with state funds, he reimbursed the stale using campagn furs “on March 11 and March 31, 2018, ‘According lo research conducted by Rosenthal. Miler spert the whole trip competing in rodeo events and won $880 doing so. Moreover. his spokesperson confirmed in an on-the-record statement thatthe trp was personal in nature. Miler’ calendar also confirmed this exchsively personal purpose, as # did not conlat any other scheduled activ les, no campaign related mestings or events rts were nol reported 2. Miller didnot report those two expenditures paid lo the slate: The article goes on to note thal these reimbursen in hiters campaign finance reports: “Miller's campaign france forms also de not record all of the Mississipp-related spending, The form Include $396 for a hole! room and $27 fora rental car bul do nol mention the campaign's payment to the state forthe fights.” —| ATTACH ADDITIONAL PAGES AS NEEDED Foms provided by Texas Ethics Commission won athics state haus Revised 1122015V. LISTING OF DOCUMENTS AND OTHER MATERIALS Page4 List all documents and other materials filed with this complaint. Additionally, list all other documents and other materials that are relevant to this complaint and that are within your knowledge, including their location, if known. Please completely fill out this form. Failure to complete this form properly will cause your complaint fo be noncompliant and rejected. = Brian Rosenthal, “Miler Used State. Campaign Funds on Trip o Compete in Rodeo," The Houston Chronicle, Apel 8, 2016 ATTACH ADDITIONAL PAGES AS NEEDED. Foms provided by Texas Eihe ‘ommior ‘wo oihvos alata tius evens 1122015VI. AFFIDAVIT Pages BASED ON PERSONAL KNOWLEDGE (Execute this affidavit if the acts alleged are within your direct personal knowledge.) Please completely fill out this form. Failure to complete this form properly will cause your complaint to be noncompliant and rejected. aoc a inant, swear that | am a resident of the state of Texas. | swear that have knowledge ofthe facts alleged in this complaint and that the information contained in this complaint is ‘tue and correct, Signature of Complainant ‘Sworn to and subscribed before me, by the said thisthe___ day of {Compiainant _ 20 ___ tocertity which, witness my hand and seal of office. Signature of cer administering ath Printed name ofoffcor administering oath “Te of otcar administering oath Vil. AFFIDAVIT [BASED ON INFORMATION AND BELIEF (Execute thie affidavit f the leged are not within your direct personal knowledge, but are based on reasonat lwoy Ste can ‘swear that | am a resident of the state of Texas. | swear that | have reason to believe and do believe that the violation alleged in this complaint has occurred, The source ‘of my information and belief is Houston) CHRONICLE NOT cot betiet) TYNN ROBINSON ES notory Publ State of Texas 9) sion Expires | “october 21. 2018 ‘of Complainant ‘Swom fo and subscribed before me bythe sad huey SEN _—tistne JE day ot ad APB 20 1 to cortty which, witness my hand and seal of office. Robonoon ROBNSON OK LATIONS Asér- Mecleheoene bya Roa — eflianle ASST