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IN THE CIRCUIT COURT FOR ETOWAH COUNTY, ALABAMA

COMPLAINT
Plaintiff Bryan Taylor brings this civil action to recover damages and obtain injunctive
relief against Defendants for defamation, false light, negligence, wantonness, and civil
conspiracy, and for his complaint alleges the following:
PARTIES
1. Plaintiff is an adult resident of Autauga County, Alabama. He is an attorney licensed
in both Alabama (since 2006) and Texas (since 2001). He is also a member of the Alabama
Senate.
BRYAN TAYLOR,

Plaintiff,

vs.

BILL BRITT; SUSAN BRITT;
ALABAMA POLITICAL REPORTER,
LLC, a domestic limited liability
company; and A, B and C, those persons,
firms, associations, corporations, or other
entities unknown to Plaintiff that acted in
concert with Defendants Bill Britt, Susan
Britt, and/or Alabama Political Reporter,
LLC, to fund, foment, direct or, jointly
with them, maliciously publish the false
and defamatory matter about Plaintiff
complained of herein,

Defendants.
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CIVIL ACTION NO. __________



PLAINTIFF DEMANDS A
TRIAL BY JURY


1
ELECTRONICALLY FILED
9/26/2014 3:30 PM
31-CV-2014-900829.00
CIRCUIT COURT OF
ETOWAH COUNTY, ALABAMA
CASSANDRA JOHNSON, CLERK
2. Upon information and belief, Defendant Bill Britt is an adult resident of Etowah
County, Alabama. He is the Editor in Chief of the Alabama Political Reporter blog and the
registered agent for and a member of Defendant Alabama Political Reporter, LLC.
3. Upon information and belief, Defendant Susan Britt is an adult resident of Etowah
County, Alabama. She is Associate Editor of the Alabama Political Reporter blog and a member
of Defendant Alabama Political Reporter, LLC.
4. Defendant Alabama Political Reporter, LLC, is a domestic limited liability company
with a registered principal address in Etowah County, Alabama.
5. Fictitious Defendants A, B, and C are those persons, firms, associations, or
corporations unknown to Plaintiff who funded, fomented, directed, or, jointly with the named
Defendants, maliciously published, or caused to be published, the false and defamatory article
complained of herein, each of whom will, upon discovery, be substituted by amendment pursuant
to Rule 9(h), Alabama Rules of Civil Procedure.
FACTS
I. The True Nature of Alabama Political Reporter
6. The named Defendants publish the Internet blog Alabama Political Reporter at http://
alreporter.com.
7. Fictitious Defendants A, B, and C fund, foment, direct, or, jointly with the named
Defendants, publish, Alabama Political Reporter.
8. Defendants publish Alabama Political Reporter by posting content to a web site in the
form of articles or columns. The type of web site is commonly known as a "blog."
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9. On Alabama Political Reporters About Us web page, Defendants promote their
blog as an ostensibly objective news source, describing its coverage with terms like accurate,
reliable, and thorough. On the same About Us page, Defendants declare:
We believe the best way to guarantee good government is to have a
fully and accurately informed citizenry. The purpose of
alreporter.com is to produce honest and accurate reporting that
informs, educates, alerts and calls citizens, lawmakers and business
leaders to action to insure the people of Alabama are represented
by the best government possible. . . .

In Alabama today, there is no single website or news organization
that provides this vital, comprehensive information service.
Therefore, we believe that by providing timely content that
addresses key daily political news and complex, longer-term
issues, along with solid reporting that digs below the surface,
alreporter.com has become the go-to source for policy makers,
opinion leaders and citizens who want to understand their
government and have a say in Alabamas future.

We believe the Alabama Political Reporter website is the
intersection at which the most powerful in politics and business
meet, therefore, making it a most desirable advertising vehicle for
those doing business in Alabama and for those wanting business
from Alabama.

We believe the core group behind this project has the experience,
Internet and news knowledge and the passion to make the Alabama
Political Reporter a success.

(Emphasis added).
10. Alabama Political Reporter further bills itself on the same About Us web page as an
independent, non-partisan media company that has positioned itself, via its robust, interactive
website, as the most trusted source for political news, analysis and commentary in the State of
Alabama. (Emphasis added).
3
11. According to the Code of Ethics of the Society of Professional Journalists, journalists
and news media organizations, in order to maintain true independence, [d]eny favored treatment
to advertisers, donors or any other special interests, and resist internal and external pressure to
influence coverage, and [d]istinguish news from advertising and shun hybrids that blur the
lines between the two. Prominently label sponsored content. http://www.spj.org/ethicscode.asp.
12. However, upon information and belief, much of the content published on the Alabama
Political Reporter blog is anything but independent, in that such content is influenced,
sponsored, or even provided by paying advertisers or their agents and, in some cases, cannot
meaningfully be distinguished from advertising, because Defendants Bill Britt and Susan Britt
(among others employed by or affiliated with Alabama Political Reporter, LLC) engage in both
writing content (i.e., reporting the news) and selling advertising from which they personally
and directly derive income and make their living.
13. Upon information and belief, notwithstanding that Alabama Political Reporter holds
itself out to be an independent and trusted source for news with the avowed purpose of
honest and accurate reporting, much of the content published on the blog, as a matter of pattern
and practice, is in the nature of unlabeled, paid political advertising masquerading as
independent, objective news coverage.
14. Upon information and belief, Defendants Bill Britt, Susan Britt and Alabama Political
Reporter, LLC, have been paid or otherwise compensated, and continue to be compensated,
directly or indirectly, in exchange for writing and/or publishing on Alabama Political Reporter
content in the nature of political advertising or electioneering communication, or with the
understanding or agreement, express or implied, that they would write and/or publish such
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content on the blog, without labeling it as advertising, for the purpose of manipulating public
opinion, influencing official action, influencing the outcome of an election, and/or embarrassing,
defaming, and/or intimidating certain persons, in furtherance of their advertisers or other
benefactors political objectives.
15. Upon information and belief, the said "core group behind this project includes paid
political/campaign consultants or operatives; lobbyists; political committees, associations, firms,
or other groups; and/or businesses or business owners, directors, managers, or investors, with a
vested interest in certain political outcomes, which they seek to advance through ostensibly
independent content published on Alabama Political Reporter.

II. The Defamatory Article
16. On or about July 1, 2014, Defendants maliciously published a false and defamatory
article on the Alabama Political Reporter blog concerning Taylor under the headline Shadowy
Conduct of the Man Who Would Be Ethics Chief (the Article). The Article is attached to this
Complaint, marked Exhibit A, and incorporated by reference.
17. The Article contains a number of maliciously false and defamatory statements,
assertions, or imputations, which the Article expressly bills as facts regarding [Taylors] ethical
conduct in public service (emphasis added), including, but not limited to, the following false
assertions or imputations, whether express or implied:
a. That Taylors conduct while employed by the State of
Alabama as personal aide to the governor was clearly
improper, unethical, and potentially criminal in that he
received additional compensation from the governors re-
election campaign committee during the same timeframe;
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b. That Taylors conduct while employed by the State of
Alabama as personal aide to the governor was clearly
improper, unethical and potentially criminal in that he was a
passenger on a state-owned aircraft during the same timeframe
that he also worked on the governors re-election campaign;
c. That Taylor, while a state employee, violated a legal duty
because [t]he Alabama Ethics Commission never received a
Statement of Economic Interest [sic] documenting Taylors
first year of work in the governors office, which would be the
duty of anyone working for the administration to file.
Disclosures should have been filed with the Alabama Ethics
Commission no later than April 30, 2007. This statement
asserts or insinuates that Taylor failed or refused to file a
mandatory Statement of Economic Interests with the State
Ethics Commission and thus imputes an illegal act or
omission;
d. That Taylor, as a state employee and later as an elected
official, has never disclosed any income from [his former law
firm], asserting or insinuating that Taylor did receive income
from his former law firm while in public office or public
employment and sought to hide it, thus imputing an illegal act
or omission;
e. That Taylor, as a member of the Republican Supermajority
in the State Legislature, has long been known . . . [to] often
blur the line between services funded by taxpayer dollars and
[his] private ventures, and frequently [to] personally profit
from State-directed contracts; that Taylor managed to rig the
system before he was even an elected official; and that Taylor
participated in these clearly unethical conflicts of interests;
thus imputing illegal acts or omissions;
f. That Taylors statement in a 2010 radio interview that he had
been practicing law prior to joining the Riley administration
raises serious questions about his role with the firm, as
records from the Alabama State Bar Association reveal that he
was not admitted to the Alabama State Bar until September
2006, seven months after he was reported to have been hired
by the Riley Administration. (Emphasis added). This
statement insinuates either that Taylor was dishonest about
practicing law or that he practiced law without a license,
thus imputing an illegal act or omission; and
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g. That Taylor has "help[ed] to direct [a former governor's]
political patronage machine," which "calls into question his
fitness to serve in any capacity charged with overseeing ethical
conduct by our public officials," insinuating that Taylor
directed corrupt patronage appointments or activity, thus
imputing illegal acts.
18. Upon information and belief, Defendants wrote and/or published the Article with the
conscious and malicious objective to interfere with or deliberately scuttle Taylors potential
candidacy for the position of Director of the Alabama Ethics Commission (also referred to as
State Ethics Director) by doing substantial harm to his reputation for honest and ethical
conduct and character in advance of the application, nomination, and confirmation process, or, at
the very least, Defendants wrote and/or published the Article with a conscious awareness and
reckless disregard of the likelihood that it would harm his potential candidacy.
19. Upon information and belief, Defendants also wrote and/or published the Article with
the conscious and malicious objective to impair his livelihood as a practicing attorney or with a
conscious awareness of the likelihood that the Article would cause harm to his personal,
business, professional, and political reputation and his livelihood.
20. Upon information and belief, in writing and/or publishing the Article, the Articles
ostensible authors, Defendants Bill Britt and Susan Britt, were not engaged in independent and
honest and accurate reporting of news, but rather were acting, in essence, as political
advertising copywriters or were otherwise acting as agents of Fictitious Defendants A, B, and/or
C.
21. Defendants consciously and deliberately failed to contact Taylor prior to publishing
the Article and thus deprived Taylor of the opportunity to correct Defendants falsehoods before
they were published.
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22. Defendants consciously or deliberately avoided discovering by any other means
whether the Article, or the statements, assertions, or imputations therein, were true or false.
23. Defendants have continued the publication of the false and defamatory Article, which
is still posted on the blog and is publicly accessible and viewable at http://www.alreporter.com/
in-case-you-missed-it-2/6462-taylor-s-ethics-questioned.html. It still appears exactly as it was
initially published.
24. In addition to publishing the Article to the Alabama Political Reporter blog,
Defendants advertised and promoted it by maliciously posting hyperlinks to the Article on social
media web sites, including Twitter and Facebook, thereby attracting even more readers to view it
and doing further harm to Taylors reputation and business/profession, and inflicting greater
embarrassment, humiliation, and emotional distress.
25. On or about July 11, 2014, Taylor, through counsel, demanded in writing, by
electronic mail and certified mail return receipt requested to Defendants Bill Britt and Susan
Britt, a retraction of the Article and the defamatory assertions therein, explaining why the matter
was false and citing the Defendants to Ala. Code 6-5-186. Defendants failed or refused to
respond to the e-mail and refused to accept the certified letter, which was returned "unclaimed,"
notwithstanding the fact that Defendant Bill Britt is the editor in chief and registered agent for
Alabama Political Reporter, LLC. A copy of Taylors letter demanding a full and fair retraction
is attached, marked as Exhibit B, and incorporated by reference.
26. Defendants failed or refused to retract, modify, or correct the Article or any of the
false statements therein and continue to fail or refuse to comply with the demand.

8
COUNT I
(Libel Per Se)

27. Taylor realleges, adopts, and incorporates the allegations in paragraphs 1 through 26
as if fully set forth herein.
28. The Article was and continues to be widely seen and read. The Article is the first
result returned upon a simple Google search on the Internet using the terms Bryan Taylor and
ethics.
29. Taken in its entirety, the Article was and is false and defamatory of Taylor.
30. The Article contains a number of defamatory statements, assertions, or imputations
which are patently false, including, but not limited to, those enumerated in paragraph 17 of this
Complaint.
31. Defendants published the Article with actual malice, in that they knew that the
defamatory matter therein was false and that the Article, taken in its entirety, was false, or they
published the Article with reckless disregard for whether the defamatory assertions therein were
true or false.
32. In addition, Defendants have allowed the Article to remain publicly accessible and
viewable on the blog even after receiving information from Taylor pointing out the inaccuracies
and falsehoods in the Article.
33. Notwithstanding that Taylor is a public figure, Defendants had no right or privilege to
publish the false and defamatory matter described herein with knowledge of or in reckless
disregard for its falsity.
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34. In accordance with Ala. Code 6-5-186, this action is commenced more than five
days after Plaintiffs written demand upon Defendants for a public retraction of the charges or
matter published, as described in paragraph 17.
35. Defendants acts complained of herein were taken by them consciously or deliberately
with regard to Plaintiff by their engagement in oppression, fraud, wantonness or malice, as
defined by Ala. Code 6-11-20.
36. As a direct and proximate result of Defendants false and defamatory Article, Taylor
has suffered damage to his good name, reputation, and livelihood as an attorney; he has been
unjustly defamed personally, professionally, and politically; and he will continue to suffer
damages in the future.
Wherefore, premises considered, Plaintiff prays that a judgment be entered in his favor
and against Defendants in an amount that is just and appropriate, including, but not limited to
compensatory and punitive damages, interest and costs, injunctive relief, reasonable attorney's
fees, and any additional relief this Court deems just and proper.

COUNT II
(False Light)

37. Taylor realleges, adopts, and incorporates the allegations in paragraphs 1 through 26
as if fully set forth herein.
38. Defendants intentionally published the Article concerning Taylor on the Alabama
Political Reporter blog and gave it additional publicity via social media including Facebook and
Twitter.
10
39. The Article was and continues to be widely seen and read. The Article is the first
result returned upon a simple Google search on the Internet using the terms Bryan Taylor and
ethics.
40. Taken in its entirety, the Article gives publicity to matters concerning Taylor in a way
that places Taylor before the public in a false light in that it depicts him as dishonest, unethical,
and corrupt, and expressly imputes illegal conduct to him, based on false and defamatory
statements, assertions, imputations, and/or omissions, including, but not limited to, the assertions
enumerated in paragraph 17any one of which, taken alone, would be enough wrongly to place
Taylor before the public in a false light; the Article expressly and wrongly asserts that these false
assertions are facts regarding his ethical conduct in public service (emphasis added) and that
they call[] into question his fitness to serve in any capacity charged with overseeing ethical
conduct by our public officials.
41. The false light in which the Article places Taylor was and is highly offensive to
Taylor and would be highly offensive to any reasonable person in Taylors position.
42. Defendants had knowledge of or acted in reckless disregard as to the falsity of the
Article and the false light in which it would place Taylor.
43. In addition, Defendants have allowed the Article to remain publicly accessible and
viewable on the blog even after receiving information from Taylor pointing out the inaccuracies
and falsehoods in the Article.
44. This action is commenced more than five days after Plaintiffs written demand upon
Defendants for a public retraction of the charges or matter published, as described in paragraph
17.
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45. Defendants acts complained of herein were taken by them consciously or deliberately
with regard to Plaintiff by their engagement in oppression, fraud, wantonness or malice, as
defined by Ala. Code 6-11-20.
46. As a direct and proximate result of Defendants publication of the Article placing
Taylor in a false light, Taylor has sustained damage to his good name, reputation, and livelihood
as an attorney; he has been unjustly defamed personally, professionally, and politically; he has
suffered embarrassment, humiliation, and emotional distress; and he will continue to suffer
damages in the future.
Wherefore, premises considered, Plaintiff prays that a judgment be entered in his favor
and against Defendants in an amount that is just and appropriate, including, but not limited to,
compensatory and punitive damages, interest and costs, injunctive relief, reasonable attorney's
fees, and any additional relief this Court deems just and proper.

COUNT III
(Negligence)
47. Taylor realleges, adopts, and incorporates the allegations in paragraphs 1 through 26
as if fully set forth herein.
48. In publishing and continuing to publish the Article concerning Plaintiff, Defendants
owed Plaintiff a duty of reasonable care to avoid making false statements, assertions, or
imputations that would unjustly defame Plaintiff or place him before the public in a false light.
49. Defendants breached this duty in publishing the Article, including, but not limited to,
the false and defamatory matter enumerated in Paragraph 17, in that they failed to contact
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Plaintiff prior to publishing the Article; they failed to take reasonable steps to verify the accuracy
of the information in the Article, they failed to take reasonable steps to verify relevant standards
or laws prior to imputing improper, unethical, criminal, or corrupt conduct to Plaintiff; and, even
after being informed by Plaintiff of the inaccuracies and falsehoods in the Article, they have
allowed the Article to continue to be published on their blog.
50. The Article was and continues to be widely seen and read. The Article is the first
result returned upon a simple Google search on the Internet using the terms Bryan Taylor and
ethics.
51. As a direct and proximate result of Defendants publication of the Article, Plaintiff
has sustained damage to his good name, reputation, and livelihood as an attorney; he has been
unjustly defamed personally, professionally, and politically; he has suffered embarrassment,
humiliation, and emotional distress; and he will continue to suffer damages in the future.
Wherefore, premises considered, Plaintiff prays that a judgment be entered in his favor
and against Defendants in an amount that is just and appropriate, including, but not limited to,
compensatory and punitive damages, interest and costs, injunctive relief, reasonable attorney's
fees, and any additional relief this Court deems just and proper.

COUNT IV
(Wantonness)

52. Taylor realleges, adopts, and incorporates the allegations in paragraphs 1 through 26
as if fully set forth herein.
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53. In publishing and continuing to publish the Article concerning Plaintiff, Defendants
owed Plaintiff a duty of reasonable care to avoid making false statements, assertions, or
imputations that would unjustly defame Plaintiff or place him before the public in a false light.
54. Defendants willfully or wantonly breached this duty in publishing the Article,
including, but not limited to, the false and defamatory matter enumerated in Paragraph 17, in that
they consciously avoided contacting Plaintiff prior to publishing the Article; consciously avoided
taking reasonable steps to verify the accuracy of the information in the Article or to verify
relevant standards or laws prior to imputing improper, unethical, criminal, or corrupt conduct to
Plaintiff; and, even after being informed by Plaintiff of the inaccuracies and falsehoods in the
Article, they consciously avoided removing the Article from the Alabama Political Reporter blog.
55. Defendants committed the willful and wanton conduct described in paragraph 55 with
conscious awareness, from their knowledge of existing conditions, that the injuries complained
of herein would likely or probably result from their conduct, and with reckless indifference to
consequences.
56. The Article was and continues to be widely seen and read. The Article is the first
result returned upon a simple Google search on the Internet using the terms Bryan Taylor and
ethics.
57. Defendants acts complained of herein were taken by them consciously or deliberately
with regard to Plaintiff by their engagement in oppression, fraud, wantonness or malice, as
defined by Ala. Code 6-11-20.
58. As a direct and proximate result of Defendants wanton and willful conduct, Plaintiff
has sustained damage to his good name, reputation, and livelihood as an attorney; he has been
14
unjustly defamed personally, professionally, and politically; he has suffered embarrassment,
humiliation, and emotional distress; and he will continue to suffer damages in the future.
Wherefore, premises considered, Plaintiff prays that a judgment be entered in his favor
and against Defendants in an amount that is just and appropriate, including, but not limited to,
compensatory and punitive damages, interest and costs, injunctive relief, reasonable attorney's
fees, and any additional relief this Court deems just and proper.

COUNT V
(Civil Conspiracy)

59. Taylor realleges, adopts, and incorporates paragraphs 1 through 58 as if fully set forth
herein.
60. Upon information and belief, Defendants agreed, contracted, combined, and/or
conspired to maliciously publish false and defamatory statements, assertions, or imputations
concerning Taylor and/or to give publicity to matters concerning Taylor in a way that would
place him before the public in a false light.
61. The intent, object, or purpose of the Defendants agreement, contract, combination, or
conspiracy was and is to do substantial harm to Taylors personal, business, professional, and
political reputation in order to interfere with or undermine Taylors potential candidacy for the
position of State Ethics Director and/or maliciously to impair his livelihood as an attorney or
otherwise cause harm to his business or profession; and/or to inflict embarrassment, humiliation,
and emotional distress on Taylor.
15
62. Defendants have committed and continue to commit certain overt acts, including
those acts described herein, with this intent and for purposes of furthering the agreement,
contract, combination and/or conspiracy.
63. As a direct and proximate result of the Defendants' conspiracy, Taylor has sustained
damage to his good name, reputation, and livelihood as an attorney; he has been unjustly
defamed personally, professionally, and politically; he has suffered embarrassment, humiliation,
and emotional distress; and he will continue to suffer damages in the future.
Wherefore, premises considered, Plaintiff prays that a judgment be entered in his favor
and against Defendants in an amount that is just and appropriate, including, but not limited to
compensatory and punitive damages, interest and costs, injunctive relief, reasonable attorney's
fees, and any additional relief this Court deems just and proper.

Respectfully submitted this the 26th day of September, 2014.
s/ Bryan M. Taylor
Bryan M. Taylor (TAY076)
Pro Se

BROM & TAYLOR, LLC
2005 Cobbs Ford Road, Suite 404
Prattville, Alabama 36066
Telephone: (334) 595-9650
Fax: (334) 610-3290
E-mail: bryan@bromtaylor.com

16














EXHIBIT A









9/26/14, 2:49 PM Shadowy Conduct of the Man Who Would Be Ethics Chief
Page 1 of 3 http://alreporter.com/politics/6462-taylor-s-ethics-questioned.html
Details 01 Jul 2014
Shadowy Conduct of the Man Who Would Be
Ethics Chief
By Bill and Susan Britt
Alabama Political Reporter
Sen. Bryan Taylor, R-Prattville, is maneuvering to become the next director of the Alabama Ethics
Commission in the wake of Jim Sumners early retirement, according to sources with knowledge of the
process.

Taylor, who decided not to seek re-election to the Alabama Senate after his first term, rose to prominence
due to the patronage of former Gov. Bob Riley. It has been reported that Riley is actively lobbying for
Taylors appointment to the Alabama Ethics Commission. However, several State Senators who served
alongside Taylor have been working behind the scenes to thwart Rileys pick for the commission.

Many of Taylor's fellow Senators have privately scoffed at the thought of Bryan Taylor as the State's
Ethics Director. The Ethics Commission is supposed to be about promoting trust and confidence in
government. These are not words that readily come to mind when referring to Taylors government
service, said one Senator in an off-the-record comment.

While colleagues opinions as to Taylors fitness to serve are important, so are the facts regarding his
ethical conduct in public service.
Taylor is said to have gotten his start in Alabama politics in February 2006, according to a statement
released by Governor Bob Rileys office in January 2007.
The press releaseannouncing Taylor's promotion to Policy Directorstates that he took a leave of
absence from Bradley, Arant, Rose & White in February 2006 to join the Riley administration as Bob
Rileys personal aide. The press statement contradicts several items, including campaign finance
documents filed by the Riley campaign in 2006 and 2007, as well as statements made by Taylor during
his 2010 campaign.
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9/26/14, 2:49 PM Shadowy Conduct of the Man Who Would Be Ethics Chief
Page 2 of 3 http://alreporter.com/politics/6462-taylor-s-ethics-questioned.html
Was Bryan Taylor working for the Riley campaign, the Riley administration, or practicing law? Public
records and official statements paint a contradictory picture.
An alumni newsletter from the University of Alabama, published in the spring of 2006, announced that
Taylor had been hired by the law firm of Bradley, Arant, Rose & White. Bob Rileys son-in-law, Rob
Campbell, is a partner at the firm. The newsletter states that Taylor was working in the firms litigation
practice group. Deidre Stalnaker, who at the time served as a communications specialist for the University
of Alabama, said the information in the newsletter was compiled between January and March of 2006.
Taylor has never publicly explained the nature of his role at Bradley Arant, Rose & White. The closest he
has come to an explanation was offered in an interview with Dan Morris in September 2010. Taylor told
Dan Morris that he was practicing law when he received a call about coming to work for Rileys re-
election campaign. This statement raises serious questions about his role with the firm, as records from
the Alabama State Bar Association reveal that he was not admitted to the Alabama State Bar until
September 2006, seven months after he was reported to have been hired by the Riley administration.
The Alabama Ethics Commission never received a Statement of Economic Interest documenting Taylors
first year of work in the governors office, which would be the duty of anyone working for the
administration to file. Disclosures should have been filed with the Alabama Ethics Commission no later
than April 30, 2007. According to a Commission employee, Taylor was not included in the list of the
governors staff that provided to the Commission. Since he started in Feb. unless someone gave him the
form to file he probably would not have known to file one, the Commission employee said. Taylors first
disclosure filing with the Alabama Ethics Commission was not received until April 30, 2008. He has never
disclosed any income from Bradley Arant or from the Riley campaign.
According to Rileys January 2007 press statement, Taylor was hired by the Riley administration as a
personal aide in February 2006. However, his receipt of campaign funds from the Riley campaign paint a
different picture. Taylor was paid $684.61 bi-weekly by the Riley campaign. These payments in this
amount began on March 31, 2006 and continued until December 29, 2006. Taylor also received additional
payments from the campaign during this time, including $925.16 in March 2006, $518.00 in July 2006,
$351.94 in October 2006 and $2,100.00 in December 2006 days before the governors office announced
his promotion to policy director.
Riley's June 45-day, Riley's June 10-day, Riley's Nov. 45-day, Riley's 10-day and Riley's Annual
The campaign expenditures from Riley present another issue for Taylor that is clearly improper, unethical,
and potentially criminal.
During the same time Taylor was a paid staffer of the Riley campaign, he was also listed numerous times
as a passenger on an aircraft owned by the State of Alabama. Flight logs maintained by the State show
that Taylor was on board a state aircraft more than 90 times in 2006. Only 7 of the 90 flights were
reported to have been reimbursed to the State, according to the flight logs. These logs also indicate that
many of the flights included campaign events for Bob Riley, and most were never noted to have been
reimbursed to the State by the campaign.
The Alabama Political Reporter has also obtained an audio recording where Taylor admits to being on
board bouncing all around the State during the campaign.
It has long been known that members of the Republican Supermajority often blur the line between
services funded by taxpayer dollars and their private ventures, and frequently personally profit from State-
directed contracts. Taylor showed himself to be ahead of many of his legislative colleagues in playing the
game of political cronyism. Bryan Taylor managed to rig the system before he was even an elected
official. Taylors participation in these clearly unethical conflicts of interest would make his proposed
nomination for Director of the Alabama Ethics Commission akin to appointing the fox to guard the
henhouse. What is certain is that Bryan Taylors tenure in the Governors office coincided with a boom in
state-directed contracts for Bradley Arant.
In 2009, a Declaration of Emergency letter was signed enabling the Riley administration to request
Bradley Arant to aide the Governors gambling task force. The contract was to last from January through
March 2009 and was not to exceed $50,000.
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9/26/14, 2:49 PM Shadowy Conduct of the Man Who Would Be Ethics Chief
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On March 9, 2009, Taylor penned a second Declaration of Emergency letter that once again hired Bradley
Arant to assist Rileys gambling task force (contract, signature page). This time the contract with Bradley
Arant was to last from March 9, 2009 through May 7, 2009 and was not to exceed $150,000. Note that
the letter and the contract date are the same.
By October 2010, the Bradley Arant contract to assist Rileys gambling task force had ballooned to
$1,250,000. (View contracts 1, contracts 2, contracts 3)

All told, the Riley administration paid Taylors former employers $2,250,000. Bradley Arant received
$6,000,000 in state contracts during that period. How much influence Taylor wielded over these decisions
is not fully known. However, his inconsistent statement of facts coupled with the Riley administration
funneling millions to his former employer raises more than a few questions about Taylors ability to head
Alabamas Ethics Commission.
Some are starting to suggest that Taylors behavior in helping to direct Bob Rileys political patronage
machine calls into question his fitness to serve in any capacity charged with overseeing ethical conduct
by our public officials.

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EXHIBIT B

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