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ARKANSAS ETHICS COMMISSION

Post Office Box 1917


LITTLE ROCK, AR 72203
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 Commission’s jurisdiction.

1. Identify the person you are complaining about:

Name: Valerie Lashell Tatumn Position or Title: Ineligibile/failed Little Rock Board
of Directors Ward 2 candidate; Ghost
Address: 5 Granite Court Phone: (Home) administrator of distressed Covenant
Keepers Charter School
Maumelle, AR 72113 (Work) 501-682-7550
Cellphone: 501-350-4009
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.
See attachment "A".

3. Attach or make reference to any documents, materials, minutes, resolutions or other evidence which
support your allegations.

State of Arkansas I swear or affirm, under penalty of perjury, that


County of ____________________ 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 Signature:


____ day of _____________, 20____.
Print your name: Russ Racop

Notary Signature: Mailing address: 301 Alamo Drive

Little Rock, AR 72211

My Commission Expires: Phone:(Home) (Work)


Cellphone: 501-352-0043
Approved by the Arkansas Ethics Commission Revised 2015
Valerie Lashell Tatum Complaint
Attachment “A”

1. On October 30, 2018 Tatum filed a prelection Campaign Contribution and Expenditure
report (“CCE”) for the period of July 31, 2018 through October 30, 2018. See Exhibit 1.
Tatum reported total monetary contributions in the amount of $34, 561 and total expenditures
in the amount of $43,261.
Tatum reported illegal contributions from Sammy J. Baker, Sr. in the amount of $10,500;
McLarty Consulting in the amount of $9.051 (see Exhibit 1, page 4) and Ugly Mike’s Records in
the amount of $6,060.
Arkansas Code Annotated §7-6-203 (a)(1)(a) prohibits any candidate for public office or any
person acting on the candidate’s behalf to accept a campaign contribution in excess of $2,700
per election from a prospective contributor. See Exhibit 2.
Tatum reported a $6,500 contribution from herself (see Exhibit 1, page 4).
Tatum violated Arkansas Code Annotated §7-6-203 (B) by accepting and reporting contributions
from prohibited contributors – McClarty Consulting and Crazy Mike’s Records. Neither of these
entities are registered in the State of Arkansas as a Political Action Committee (“PAC”).
Tatum reports expenditures in the amount of $43,261 but her CCE only details $14,760 in
expenditures - $6,060 in unspecified “fund-raising expenses” and $8,700 in payments to
campaign workers (see Exhibit 1, page 6). This report claims $34,561 in itemized expenditures
but $19,801 in expenditures are undocumented see Exhibit 1, page 7).
Tatum claimed in an article published by Max Brantley with the Arkansas Times that others
prepared the report, though she signed and attested it was “complete, true and accurate.” See
Exhibit 3.
Based on an affidavit of candidacy Tatum filed with the Little Rock City Clerk (see Exhibit 4) the
handwriting on the CCE filed on October 30, 2018 appears to be Tatum’s own handwriting.
2. On October 31, 2018 Tatum filed an amended CCE. See Exhibit 5.
Tatum now reported total monetary contributions in the amount of $13, 495 and total
expenditures in the amount of $43,261.
Tatum lists an illegal loan in the amount of $7,800 from Sammy J. Baker, Sr. (see Exhibit 5, page
2) and she reports an additional $2,700 contribution from him (see Exhibit 5, page 4.

1
Arkansas Code Annotated §7-6-203 (c) only permits loans from a candidate or personal loans
from a financial institution to the candidate to be applied to the campaign.
Tatum reported an illegal contribution in the amount of $1,845 from Crazy Mike’s Records. On
her CCE filed the previous day she reported a contribution in the amount of $6,060 from this
illegal contributor.
Tatum violated Arkansas Code Annotated §7-6-203 (B) by accepting and reporting this
contribution from a prohibited Crazy Mike’s Records is not registered in the State of Arkansas
as a Political Action Committee (“PAC”).
Tatum reported $29, 766 in expenditures on her amended CCE (see Exhibit 5, page 6) where on
the one filed the previous day, she reported only $6,060.
Tatum reports itemized campaign expenditures totally $22,195 but does not account for
$21,066 in expenditures on this CCE (see Exhibit 5, page 7).
Again, based on an affidavit of candidacy Tatum filed with the Little Rock City Clerk (see Exhibit
4) the handwriting on the amended CCE filed on October 31, 2018 appears to be Tatum’s own
handwriting.
Another article published by Max Brantley with the Arkansas Times on November 5, 2018
pointed out problems with Tatum’s original CCE and amended CCE. See Exhibit 6.
3. On March 2, 2018 Tatum filed an Exploratory Committee Registration form (“ECR”) listing
the name of the committee as “Valerie Tatum LR City Council”. See Exhibit 7.
Again, based on an affidavit of candidacy Tatum filed with the Little Rock City Clerk (see Exhibit
4) the handwriting on the ECR appears to be Tatum’s own handwriting.
4. On July 25, 2018 Tatum filed a CCE (See Exhibit 8) which appears to be for contributions
made to her “Valerie Tatum LR City Council” exploratory committee. Total monetary
contributions were listed as $1,345 (see Exhibit 8, page 1) with expenditures for paid campaign
workers as $650 (see Exhibit 8, page 6) leaving a balance of $695.
The funds collected by Tatum’s exploratory committee were not reported on the CCE filed on
October 30, 2018 or her amended CCE filed on October 31, 2018. See Exhibits 1 and 5.
Tatum also failed to properly list place of business or employer/occupation of financial
contributors on CCE’s filed in October 2018.
---
Based on a preponderance of the evidence, the Commission should make a finding that Tatum
violated Arkansas Code Annotated §7-6-203 and have an appropriate sanction applied to her.

2
CAMPAIGN CONTRIBUTION AND EXFENDITURE REPORT
For County, Municipal and SchoolBoard Candidates

! Check if this report is an amendment


should be filsd with the Clerk of the in which the election is held
Candidate
I (Y-t

{Clerk's Fite

Does the have a campaign comrhittee? )Yes ( )No


If te the fol

bl*c: f-iLiii 1'i,i3ijr'i';-j iut 1'1:r-irriiit


'L;;;":,
i;=;; i.*i:=.1:i
il''i
;i*rr,
2. Type of Election: {check onlyone} , Year of Election__3f1i[
[1 Primary D Primary Runoff XGenerat fl General Runoft
Annualschi:ol il Annual School Runaff
3. Type of Report: (check one) This report covers wtrat period? { t|ll$raug 0\t 7
*l
,tr Preeleclion report *lf lhe campaign has nol
Final report (check method by which surplus campaign funds were disposed)" ended, disposal of
ilTreasurer of State (for benefit of General Revenue Fund Account of the $tate Apportionment Fund) campaign funds is not
U A politicat party as defined in Ark. Code Ann. $ 7-1-101 or a political party caucus of lhe Arkansas General required and lhe
Assembly, the Senaie, or the House of Representatives candidate may carry
E Contributors to the candidate's campaign forward any remainlng
n A nonprofit organization that is exempt from taxation under Section 501(c){3) of ihe lntemal Revranue Code campaign funds lo the
n Citles of the first class, cities of trE second class, or incorpcrated torvns next election in the cycte
for that same office.

CUIIULATIVE TOTAL
4. Balance of ca funds at
5. lnterest earned 0n cam n account
6. Total Loans (enter total from line I
7. Total Contributions (enter total from line
8. Total enter totalfrom line
9. Balance of funds at close of
'10. lf this is candidate's final report for an election, amount of carryover
funds or outstanding indebtednesS {use brackets to indicate
1 1 " ( ) NO ACIVITY lcnecx f you have not received contribrrtions, expenditures dunng this r€porting peilsd)

I certify to the best of my knowledge and belief that the i is a complete, true, and accurate
financial statement of my (the candidate's) campaign

Swom lo and subscrib€d before Connty, Arkansas, on this

.W-ffi:tu My Commission Expires:

Ark. Code Ann, $ 7-&202 provides that a person \,rho knowingty fails to comply Wth the provisions of subchapter 2 of chapter 6, Title 7 of the Arkansas Code
shdl upon convictlon be guilty of a class A misdemeanor

111
REVT'ED 08/2015

Tatum Complaint - Exhibit 1, Page 1 of 8


{2. LOAN INFORMATION
Please Typa or Print
Do not list loans previously reported

NAME AND ADDRESS OF LENDING

TOTAL LOANS DURING REPORTING

IMPORTAN?

The lirnits on campaign contributions do not apply to loans or contributions made by a


candidate from his or her owil per$oftal funds to the campaign or to personal loans
made by financial institutions to the candidate and applied to his or her campaign. Any
loans made by a candidate to his or her campaign and any loans rnade by a financial
institution to a candidate and applied to his or her carnpaign shall be reported in Section
12.

lf a candidate desires to use or raise campaign funds to repay himself or herself for
personal funds which he or she contributed to the campaign, then he or she would need
to report those personal funds as a loan in $ection 12.

lf a candidate does not desire to use or raise campaign funds to repay himself or herself
for personal funds which he or she contributed to the campaign, then those personal
funds would not be reported in Section 12. lnstead, they would be reported as a
campaign contribution either in Section 1S or on line 18, depending upon the ar*ount.

lf a candidate has unpaid laans at the end of the primary, runoff, special, or general
election, the source, description and amount of each such loan should be itemized in
Section 29. Candidates ending their campaign in debt are permitted to raise funds to
retire the debt subject to the restrictions contained in Ark. Code Ann. $ 7-6-219.

Ark. Code Ann. S 7-6'202 provides lhat a person who knoningly fails to comply with the provisions of subchapter 2 of chapter 6. Title T of the Akansas Code
shall Upon convlcUon be guiity of a Class A misdemeanor.
REVISED O8i2O15

Tatum Complaint - Exhibit 1, Page 2 of 8


14. NONMONEY CONTRIBUTIONS
Does not inckde volmteer services by individuals

Value of nonmoney
item

TOTAL NONMONEY CONTRIBUTIONS

IMPORTA[fr

ln addition to monetary contributions, candidates are required to report the


receipt of any nonmonetary ("in-kind") contributions. A candidate receives an in-
kind contribution whenever a contributor provides him with an itern or service
without charge or for a charge that is less than the fair rnarket value of the item
or service in question.

The value of an in-kind contribution is the difference between the fair market
value and the amount charged. ln-kind contributions are addressed in greater
detail in Sections 205 and 206 of the Commission's Rules on Campaign Finance
& Disclosure.

Ark. Code Ann. $ 7€'202 provides that a p€rson u/iro knowingty fails to comply with the provisions of subchapter 2 of chapter 6. Tille 7 of the Artansas Code
shall upon conuiction be ouilty of a Class A misdemeanor.
REVtSfiD 0812015

Tatum Complaint - Exhibit 1, Page 3 of 8


16. ITEMIZED MONETARY CONTRIBUTIONS OVER $50
Please Type or Prtnt
Use cooies of this Daoe as
Full Name and Mailing Address of Contributor Ournulative Total
From This
Contrlbutor

w 5 'le bnnrwl il&aof S^,


Tc,soo o
lC, 5oc
q,n d )a*wr trore b 1:b0,oo ,b r15' , ou
5hr+" 0&i'fr'
01 ?o ,$ { lo0 ,s Gla0,"o

snfu!8 0*5{dd,accx fuwt .


,500,n0 +,oQ,uu

nl,,ltb )ue Pl, V ul:intn s 4 i000,:' 6laao,"

nbl', Ant4w 4 tscfl 4 {oo,w

Uel"i^'t Jnt*lln i 1,CIr. @ uq,a sl


,
oo

I
Vafu*,e fr*..,c.* s
l*,|ac ,9q lo, foo,oo

5cl
Subtotal of Contributions This Pa

Ark. Code Ann. S 7-S202 provides that a person who kilowingly fails to comply wilh the provisions of subchapter ? of c+Hpter 6, Title 7 of the Arkansas Code
Shall upon conviction be guilty of a Class A misd€meaf}or.
REVISED O8i2O15

Tatum Complaint - Exhibit 1, Page 4 of 8


ITEMIZED I''ONETARY CONTRIBUTIONS OVER $50
Please Tvoe or Print
Full Name and Mailing Address of Contributor

LolS ( * a, *;',\D^+,'dyL s oo
ft+ ^'l lr, ArD
@-

Dceneral n Oebl

trPrimary tr Run-Off
trGeneral tl Debt

trGeneral fl Debt

17. TOTAL ITEMIZED MONETARY CONTRIBUTIONS OVER


18. TOTAL NONITEMIZED MONETARY CONTRIBUTIONS
{9. TOTAL TI'IONETARY CONTR}BUTION$ THIS REPORT
(includes totals from lines l7 and 18!

Ad( Code Ann. $ 7-6-202 provides that a person who knowingly fails to comply !,{ith lhe proyisions of subchapter ? of chapter 8, Tille 7 of the Arkansas Code
shall upon convictiofl be guilty of a Class A misdemear.lor.
REVISED 08/2015

Tatum Complaint - Exhibit 1, Page 5 of 8


20. CAMPAIGN EXPENDITURES BY CATEGORY
F/ease Type or Print

CATEGORY TOTAL AMOUNT


Fee
Television

Other Adverti
Office Supplies

Utitities
T

Direct Mail
Travel
Entertainmenl

Loans
Retrlrned Contributions
Consultant Fees
Polls
Paid t
ffi

21. TOTAL GAIUIPAIGN EXPENDITURES

2I, PAID CAMFAIGN WORKERS


NAME CIF WORKER

23. TOTAL PAID GAMPAIGN WORKERS

Ark. Code ,Ann. $ 7-6-202 provides lhat a p€rson v\ho knoivingly fails to comply wilh the provisions of subchapter 2 of chapter S" Tille 7 of the Arkansas Code
shall upon conviction be guifry of a Class A misdemeanor.
REVTS=D 08t2015

Tatum Complaint - Exhibit 1, Page 6 of 8


24, ITEMIZED CAMPAIGN EXPENDITURES OVHR $1OO
Please Type or Print

Name end Address of

25. TOTAL ITEMIZED EXPENDITURES THIS REPORT


26. TOTAL HO}'IITEMIZEB EXPENDITURES THIS REPORT
27. TOTAL PAID CAMPAIGN WOR.KERS THI$ REPORT amount from line
28. TOTAL EXPENDITURES THIS

NOTE: Expenditures Reflected on Line$ 25JG and 27 Should EF Tp*,aled bv Cateqory in,qpction 20

Ark- Code Ann. $ 7-6-202 provides ihat a person who *nowingly fails to comply with the provisions of subchapter 2 of chapter 6, Title 7 ol the Arkansas Code
shall LFon convieticn be guilty of a Class A misdemeanor.
REVISED O8T2OI5

Tatum Complaint - Exhibit 1, Page 7 of 8


29. OUTSTANDING CAMPAIGN DEBTS
{including unpaid loans}
To Be Gompleted On Candidate'e Final Report For An Election
Please Type or Print
Use a#r?ionarpaoes if ,lecessary

NAMEANB

TOTAL DEBT

Ark, Code Ann. S 7-C2O2 provides that a p€rscn wlu knowingiy fails to comply rjyith Itle provisiocs of subchapler 2 of chapter 6, Tifle ? ot the Ar*ansas Code
shall upon convicti$ be guilty of a Class A misdemeafior.
REVTSED 081201s

Tatum Complaint - Exhibit 1, Page 8 of 8


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Code of Arkansas Public Access More

Document: A.C.A. § 7-6-203

22

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A.C.A. § 7-6-203

Copy Citation

Current through all laws of the 2018 Fiscal Session and 2018 Second Extraordinary
Session, including changes and corrections by the Arkansas Code Revision Commission.

Arkansas Code Annotated Title 7 Elections Chapter 6 Campaign


Practices Subchapter 2-- Campaign Financing

7-6-203. Contributions -- Limitations -- Acceptance or


solicitation -- Use as personal income -- Disposition.
(a) (1) (A) It shall be unlawful for any candidate for any public office or for any person
acting on the candidate's behalf to accept campaign contributions in excess of two
thousand seven hundred dollars ($2,700) per election from:
(i) An individual;
(ii) A political party that meets the definition of a political party under § 7-1-101;
(iii) A political party that meets the requirements of § 7-7-205;
(iv) A county political party committee;
(v) A legislative caucus committee; or
(vi) An approved political action committee.
(B) It shall be unlawful for a candidate for a public office or for any person acting on the
candidate's behalf to accept a campaign contribution from a prospective contributor other
than those under subdivisions (a)(1)(A)(i)-(vi) of this section.
(2) A candidate may accept a campaign contribution or contributions up to the maximum
amount from any prospective contributor under subdivisions (a)(1)(A)(i)-(vi) of this
section for each election, whether opposed or unopposed.
(b)
(1) It shall be unlawful for any person permitted to make a contribution under
subdivisions (a)(1)(A)(i)-(vi) of this section to make a contribution to a candidate for any
public office or to any person acting on the candidate's behalf, which in the aggregate
exceeds two thousand seven hundred dollars ($2,700) per election.
(2) A person permitted to make a contribution or contributions under subdivisions (a)(1)
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(A)(i)-(vi) of this section may make a contribution or contributions up to the maximum


amount to a candidate for each election, whether opposed or unopposed.
(c) The limitation shall not apply to loans made by a candidate from his or her own
personal funds to the campaign, contributions made by a candidate from his or her
personal funds to the campaign, or to personal loans made by financial institutions to the
candidate and applied to his or her campaign.
(d)
(1) It shall be unlawful for any candidate for any public office or any person acting in the
candidate's behalf to accept any contribution from a prohibited political action committee
for any election.
(2) It shall be unlawful for any prohibited political action committee to make a
contribution to a candidate for public office in an election.
(3) It shall be unlawful for any ballot question committee, legislative question committee,
political party, county political party committee, or approved political action committee to
accept any contribution from a prohibited political action committee.
(4) It shall be unlawful for any prohibited political action committee to make a
contribution to:
(A) A ballot question committee;
(B) A legislative question committee;
(C) A political party;
(D) A county political party committee; or
(E) An approved political action committee.
(e) It shall be unlawful for any candidate for public office, any person acting in the
candidate's behalf, or any exploratory committee to solicit or accept campaign
contributions more than two (2) years before an election at which the candidate seeks
nomination or election. This subsection shall not prohibit the solicitation or acceptance of a
contribution for the sole purpose of raising funds to retire a previous campaign debt.
(f) (1) A candidate shall not take any campaign funds as personal income. This
subdivision (f)(1) shall not apply to campaign funds that were:
(A) Accumulated prior to the passage of Initiated Act 1 of 1990; or
(B) Disposed of prior to July 28, 1995.
(2) A candidate shall not take any campaign funds as income for his or her spouse or
dependent children, except that:
(A) This subsection shall not prohibit a candidate who has an opponent from employing
his or her spouse or dependent children as campaign workers; and
(B) Any candidate who has an opponent and who, during the campaign and before the
election, takes a leave of absence without pay from his or her primary place of
employment shall be authorized to take campaign funds during the campaign and before
the election as personal income up to the amount of employment income lost as a result of
such leave of absence.
(3) A candidate who takes campaign funds during the campaign and before the election
under a leave of absence pursuant to the provisions of subdivision (f)(2) of this section
may elect to treat the campaign funds as a loan from the campaign fund to the candidate
to be paid back to the campaign fund by the candidate.
(4)
(A) For purposes of this subsection, a candidate who uses campaign funds to fulfill any
commitment, obligation, or expense that would exist regardless of the candidate's

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campaign shall be deemed to have taken campaign funds as personal income.


(B) The use of campaign funds to purchase a cake or other perishable item of food at a
fund-raising event held by a volunteer agency, as defined in § 16-6-103, shall not be
considered a taking of campaign funds as personal income.
(C) The use of campaign funds to purchase advertising prior to the date the final report is
due to be filed thanking voters for their support shall not be considered a taking of
campaign funds as personal income.
(D) The use of campaign funds to pay a candidate's own personal expenses for food,
lodging, or travel to attend a national presidential nominating convention shall not be
considered a taking of campaign funds as personal income.
(g) (1) Within thirty (30) days following the end of the month in which an election is held
or a candidate has withdrawn, a candidate shall turn over surplus campaign funds to
either:
(A) The Treasurer of State for the benefit of the General Revenue Fund Account of the
State Apportionment Fund;
(B) A political party as defined in § 7-1-101 or a political party caucus of the General
Assembly, the Senate, or the House of Representatives;
(C) A nonprofit organization that is exempt from taxation under Section 501(c)(3) of the
Internal Revenue Code;
(D) Cities of the first class, cities of the second class, or incorporated towns; or
(E) The contributors to the candidate's campaign.
(2) If the candidate's campaign has not ended, disposal of surplus campaign funds shall
not be required and the candidate may carry forward any remaining funds to the general
primary election, general election, or general runoff election for that same office.
(3)
(A) If an unopposed candidate agrees not to solicit further campaign contributions by
filing an affidavit declaring such an agreement, the candidate may dispose of any surplus
campaign funds prior to a general election as soon as the time has passed to declare an
intent to be a write-in candidate pursuant to § 7-5-205.
(B) For an unopposed nonpartisan candidate, the affidavit may be filed after the
deadlines have passed to declare as a filing fee candidate, petition candidate, or write-in
candidate under § 7-10-103.
(C) The affidavit shall be filed in the office in which the candidate is required to file
reports of contributions received and expenditures made.
(D) Unopposed candidates and defeated candidates who file the affidavit are exempt from
further reporting requirements provided that the affidavit contains:
(i) All campaign activity not previously reported; and
(ii) A statement that the candidate's campaign fund has a zero ($0.00) balance.
(4)
(A) Carryover funds may be expended at any time for any purpose not prohibited by this
chapter and may be used as campaign funds for seeking any public office. Nothing shall
prohibit a person at any time from disposing of all or any portion of his or her carryover
funds in the same manner as for surplus campaign funds. However, the candidate shall not
take the funds as personal income or as income for his or her spouse or dependent
children.
(B)
(i) When a person having carryover funds files as a candidate for public office, his or her

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carryover funds shall be transferred to the person's active campaign fund. Once
transferred, the funds will no longer be treated as carryover funds.
(ii) This subdivision (g)(4)(B) shall not apply to carryover funds from an election held
prior to July 1, 1997.
(iii) This subdivision (g)(4)(B) shall not apply to a campaign debt.
(C)
(i) If carryover funds are expended prior to transferring the funds to an active campaign
fund, the expenditures shall be reported pursuant to this subdivision (g)(4)(C). A person
shall file an expenditure report concerning carryover funds if, since the last report
concerning the carryover funds, the person has expended in excess of five hundred dollars
($500). The report shall be filed at the office in which the candidate was required to file his
or her campaign contribution and expenditure reports for the previous campaign not later
than fifteen (15) days after a calendar quarter in which a report becomes required. No
report is required in any calendar quarter in which the cumulative expenditure limit has
not been exceeded since the person's last report.
(ii) The person shall also file an expenditure report for the calendar quarter in which he or
she transfers the carryover funds to an active campaign fund.
(iii)
(a) A person who retains carryover funds shall file an annual report outlining the status of
the carryover fund account as of December 31 unless the person has filed a quarterly
report during the calendar year pursuant to subdivisions (g)(4)(C)(i) and (ii) of this
section.
(b) The annual report shall be due by January 31 of each year.
(c) A person who retains carryover funds from a general election held in November or a
runoff election held in November is not required to file an annual report for the year of the
general election or runoff election from which carryover funds were retained.
(iv) The carryover fund reports of a candidate for school district, township, municipal, or
county office shall be filed with the county clerk of the county in which the election was
held.
(v)
(a) The carryover fund reports of a candidate for state or district office shall be filed with
the Secretary of State.
(b) The carryover fund reports of a candidate for state or district office filed with the
Secretary of State shall be filed in electronic form through the official website of the
Secretary of State. The Arkansas Ethics Commission shall approve the format used by the
Secretary of State for the filing of carryover fund reports in electronic form under this
subdivision (g)(4)(C)(v)(b) to ensure that all required information is requested. The official
website of the Secretary of State shall allow for searches of carryover fund report
information required to be filed in electronic form under this subdivision (g)(4)(C)(v)(b).
(D)
(i) Carryover funds may be retained by a person for not more than ten (10) years after
the last election at which he or she was a candidate, or if applicable, not more than ten
(10) years after the last day that the person held office, and any remaining carryover
funds shall be disposed of in the same manner as for surplus campaign funds.
(ii)
(a) The officer with whom the person last filed a final campaign report shall provide the
person timely notice of the requirements of this subdivision (g)(4)(D) prior to the

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expiration of the ten-year period.


(b) However, failure to provide the notice does not relieve the person of his or her
obligation under this subsection.
(5) After the date of an election at which the person is a candidate for nomination or
election, the person shall not accept campaign contributions for that election except for the
sole purpose of raising funds to retire campaign debt.
(6) Surplus campaign funds or carryover funds given to a political party caucus shall be
segregated in an account separated from other caucus funds and shall not be used:
(A) By the political party caucus to make a campaign contribution; or
(B) To provide any personal income to any candidate who donated surplus campaign
funds or carryover funds.
(h) A candidate may maintain his or her campaign funds in one (1) or more campaign
accounts. Campaign funds shall not be placed in an account containing personal or
business funds.
(i)
(1) The contribution limits under subdivision (a)(1)(A) and subdivision (b)(1) of this
section shall be adjusted at the beginning of each odd-numbered year in an amount equal
to the percentage certified to the Federal Election Commission by the Bureau of Labor
Statistics of the United States Department of Labor under 52 U.S.C. § 30116(c) as existing
on January 1, 2015.
(2) If the amount after adjustment under subdivision (i)(1) of this section is not a
multiple of one hundred dollars ($100), the Arkansas Ethics Commission shall round the
amount to the nearest multiple of one hundred dollars ($100).
(3) The Arkansas Ethics Commission shall promulgate rules identifying the adjusted
contribution limit under subdivision (i)(1) of this section.

History

Acts 1975, No. 788, § 2; 1977, No. 312, § 6; 1981, No. 690, § 1; A.S.A. 1947, § 3-1110;
Init. Meas. 1990, No. 1, §§ 2, 3; Acts 1993, No. 1195, § 1; 1993, No. 1196, § 1; 1995,
No. 863, §§ 1-3; 1995, No. 1296, § 41; Init. Meas. 1996, No. 1, §§ 2, 3; Acts 1997, No.
116, § 1; 1997, No. 491, §§ 2, 3; 1999, No. 553, § 3; 1999, No. 1057, § 1; 2001, No.
954, § 1; 2001, No. 1839, § 2; 2003, No. 195, §§ 2, 3; 2003, No. 248, § 1; 2005, No.
1284, §§ 3, 4; 2005, No. 1413, § 1; 2005, No. 1695, § 1; 2007, No. 221, § 2; 2009, No.
340, § 1; 2009, No. 473, §§ 3, 4; 2009, No. 1204, § 2; 2011, No. 721, §§ 3, 4; 2013, No.
382, § 1; 2013, No. 1110, § 7; 2015, No. 142, § 1; 2015, No. 1280, §§ 5-7; 2017, No.
318, § 1.

Arkansas Code of 1987 Annotated Official Edition


© 2018 by the State of Arkansas All rights reserved.

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Tatum Complaint Exhibit 2, Page 5 of 5

5 of 6 11/14/2018, 9:12 AM
Corrections needed on City Board candidate's campaign filing UPDATE ... https://www.arktimes.com/ArkansasBlog/archives/2018/10/31/correction...

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Corrections needed on City Board candidate's campaign filing UPDATE


Posted By Max Brantley on Wed, Oct 31, 2018 at 7:26 AM

Perusing campaign finance filings yesterday, I discovered multiple problems on the click to enlarge

report filed by Valerie Tatum, a candidate for Ward 2 on the Little Rock City Board,
who already faces questions over her eligibility to run for the seat. UPDATE: She has
filed an amended report.

You can see her report in full here.

There were these obvious issues:

* She reported contributions of $10,500 from Sammy J. Baker Sr. and $9,051 from
McLarty Consulting. The state law limits individual contributions to $2,700. It also
VALERIE TATUM: Promises to correct initial
prohibits corporate contributions. campaign filing.

* She reported $6,050 in "fund-raising donations" attributed under the "place of business" column to Ugly Mike's
Records. This sounds like a contribution kitty maintained at a place of business. That method of fund-raising, without
itemization, is frowned on by the state Ethics Commission. This issue remains unclear. If a single contribution from the
record store, it is illegal.

Other basic bookkeeping problems turned up. The report says she's made $43,261 in expenditures, but the report
breaks out far less — $6,060 in unspecified "fund-raising expenses" and $8,700 in payments to campaign workers. The
report claims more than $34,000 in "itemized" expenditures, but no others are itemized beyond the $14,760 worth.

The report summary claims more than $34,000 in "itemized" contributions though it includes that unsourced amount
from Ugly Mike's. The report said Tatum had also put $6,500 personally in the race. Candidates may spend an unlimited
amount of their own money, though they often do so in the form of a loan so that they might raise money to pay
themselves back.

I reached Tatum by telephone yesterday and her responses to questions were muddled. She said others prepared the
report, though she signed it and attested it was "complete, true and accurate." She said she'd be filing an amended
report today, but had wanted to meet "due diligence" by filing a timely report yesterday. "I'll get it cleaned up
tomorrow," she said.

I couldn't get direct answers to questions about several points. The McLarty "contribution" perhaps should have been
listed as an expenditure rather than a contribution, she seemed to suggest. It is a political consulting firm. The Ugly
Mike money? I couldn't get a clear response.

Tatum has had bookkeeping problems before. When she led the Covenant Keepers Charter School, a charter school
panel recommended revoking its charter because of governance, financial and management issues. The pro-charter
state Board of Education overturned the recommendation. Charter school backer, Claiborne Deming, the wealthy former

Tatum Complaint Exhibit 3, Page 1 of 3

1 of 3 11/14/2018, 8:40 AM
Corrections needed on City Board candidate's campaign filing UPDATE ... https://www.arktimes.com/ArkansasBlog/archives/2018/10/31/correction...

Murphy Oil executive from El Dorado, was an early contributor of $1,000 to Tatum's campaign. She says she's "retired"
from the charter school, where she'd been accused in 2015 of self-dealing.

Tatum enjoys some campaign support from prominent members of the Little Rock business establishment  — $750
from John and Shayla Copas, $500 from Gary and Rebecca Smith and $1,000 from Gus Vratsinas, all in the construction
business.

City Attorney Tom Carpenter has said Tatum isn't eligible to run for Ward 2 against incumbent Director Ken
Richardson because when she filed she claimed a residence outside the ward. She moved to an address inside the ward
after that was reported, though Carpenter says the law requires proper residency to become a candidate. The City Board
has refused to take action over her candidacy.  She's been represented legally in fighting Carpenter's opinion by Jess
Askew, a lawyer who often represents charter school, school choice and similar interests of the powerful school lobby
led by the Walton Family Foundation.

I tried to find out from Tatum if she still owned the house in Maumelle that she has long claimed as a residence and on
which she has claimed a homestead property tax exemption this year. She declined to answer questions about it. "I'd
rather not," she said.

UPDATE: She filed an amended report Wednesday. You can see it here. It still confuses me.

Instead of a $10,500 contribution from Baker, she now reports a $2,700 contribution and a $7,800 loan. She describes
him as a relative. The law says:

Where she had reported $6,050 from Ugly Mike's she now reports $1,845.

Where she had reported more than $9,000 from McLarty Consulting, she now reports that as expenditures on campaign
services to the political consulting firm.

She discloses a loan repayment, person or entity unspecified, of $7,800.

In all, the report now says she has spent $43,261 will raising only $13,495 in contributions. The ony lending on the firm
is the amount reported from Baker. Some forensic accounting is needed here.
Tags: Little Rock City Board, Ward 2, Valerie Tatum, campaign finance law, illegal contributions, state Ethics Commission, Image

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Tatum Complaint Exhibit 3, Page 2 of 3

2 of 3 11/14/2018, 8:40 AM
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Tatum Complaint Exhibit 3, Page 3 of 3

3 of 3 11/14/2018, 8:40 AM
4 Tatum Complaint Exhibit 4
CAMPAIGN CONTRIBUTION AND EXFENDITURE REPORT
For County, Municipal and $choolBoard Candidates

ffCneck if this report is an amendment


Ihi! report should be filed with the County Clerk of the county in which the election is held
1. Natne of Candidde
tl**rp, 'la*"rn
Add+ess -->
140, a ,\aaft
"fld*nro1 ,850..1-oo
File Stamp)

Does the have a campaign committee? ( 1)Yes ( )No


nf
reasurer:

tt
2. Type of Election: (check onryont). Year of Eleciion-6[,Cl_]
riLtii iij,i*r1,'lij 1il: i_E: I!
L*irJ tlr*i'r* Fule:.ili r;ir,:uit ill*ril
D Primary fl Frimary Runoff 0[General f] General Runoff
AnnuatSchool il AnnualSchool Runoff

Type of Report: (check one) This report covers what period? f/ tot t tflthrough tO t4 gP $
(?, - Preeleciion report <

"lf lfE campa\?n has nol


tr' Finat report {check method by which surptus campalgn funds were disposed}n ended, disposal ol
il Treasurer of State (for benefit of General Revenue Fund Account sf the State Apportionment Fund) campaign funds is not
tr A political party as defined in Ark. Cde Ann. $ 7-1-101 or a political party ceucus of the Arkansas General requi.ed and lhe
Assembly, the Senate, or the House of Repre$entatives candidate may carry
D Contributors to the candidate's campaign forward any remaining
tr A nonprofit organization that is exempt frorn taxation under Section 501(cXg) of the lntemal Relrenue Code campaign funds to lhe
n Cities of the first class, cities of the second class, or incorporated towns ftext election in the cycte
for that same ofice.
Su
UMMARY
4. Balance of ca n funds at beqinnino of
5. lnterest {if anv) earned on ca account
6. Total Loans (enter total from line t2
7. Total Contributions (enter total from line 1

8. Total enter iotalfrom line


9. Balance of campaion funds at close of
10. lf this is candidate's final report for an election, amount of carryover
funds or indebtednesS {use brackets to indicate
{ L ( } NO ACT|VITY lcnecX if you have nol received contribr.rtions, loans, or made eryerdiiures during this reporling period)

I certify to the best of my knowledge and belief that the is a complete, true, and accurate
financial statement of my (the candidate's) campaign

, County, Arkansas, on this*:2ll day of

G#ffi*
*$1l'**iiHr.}r#
mus( 6e leglble (1.e., elther sfamped or

Ark. Code Ann, S 7-&202 provides lhat a person v,tro knowingty fails to comply with the provisions of subclrapter 2 oI chapter 6, Title 7 of the Arkansas Csde
shall upon convictlon be guilty of a Class A misdemeanor.
REVISED 06/2015
5
Tatum Complaint Exhibit 5, Page 1 of 8
12, LOAN INFORMATION
Flease Type or Print
Do not list loan$ previously reported

AND ADDRESS OF LENDING INSTT AMOUNT

l0.5.,lpib S**,\'SBz" & o o,'

13. TOTAL LOANS DURING REPORTING

IMPORTANT

The limits on campaign contributions do not apply to loans or contributions made by a


candidate from his or her own personal funds to the campaign or to personal loans
made by financial institutions to the candidate and applied to his or her campaign. Any
loans made by a candidate to his or her campaign and any laans made by a financial
institution to a candidate and applied to his or her campaign shall be reported in Section
12.

lf a candidate desires to use or raise campaign funds to repay himself or herself for
personal funds which he or she contributed to the campaign, then he or she would need
to report those personal funds as a loan in Section 12.

lf a candidate does not desire to use or raise carnpaign funds to repay himself or herself
for personal funds which he or she contributed to the campaign, then those personal
funds would not be reported in Section 12. lnstead, they would be reported as a
carnpaign contribution either in Section 16 or on line 18, depending upon the amount.

lf a candidate has unpaid loans at the end of the primary, runoff, spocial, or general
election, the source, description and arnount of each such laan should be itemized in
Section 29. Candidates ending their carnpaign in debt are permitted to raise funds to
retire the debt subject to the restrictions contained in Ark. Code Ann. $ 7-&219.

Ark. Code Ann. S 7-S202 provides that a person who knowirEly fails to comply with the provisions of subchapter 2 of chapter 6, Title 7 of the Artansas Code
shall upon convictlon be guiffy of a Class A misdemeanor.
REVISED O8I2O.I5

Tatum Complaint Exhibit 5, Page 2 of 8


14. NONMONEY CONTRIBUTIONS
Does not include vdunteer services by individuals

Full Name and AddrBSs of Contributor Cumulative Tctal

rMPORrAlfr

ln addition to monetary contributions, candidates are required to report the


receipt of any nonmonetary {"in-kind'i contributions. A candidate receives an in-
kind contribution whenever a contributor provides him with an item or service
without charge or for a charge that is less than the fair market value of the item
or serviee in question.

The value of an in-kind contribution is the difference between the fair market
value and the amount charged. ln-kind contributions are addressed in greater
detail in Sections 205 and 206 of the Commission's Rules on Campaign Finance
& Disclosure.

Ark. Code Ann. S 7€-202 provides lhat e person who knorvingly fails to comply wilh the provisions of subchapter 2 of chapter S. Tille 7 of the Arkanses Code
shall upoil conviclion be guilty of a Class A misdemesnor.
REVTSED 0812015

Tatum Complaint Exhibit 5, Page 3 of 8


16. ITEMIZED MONETARY CONTRIBUTION$ OVER $50
Please Type ar Print
of llris Da0e as
Date full Name and Mailing Addrss of Contributor Place Of Buslness Amountof Cumulative Total
Employerl0ccupation Contribution From This
Contributor
trPrimary D Run-Off
"1"]et;"n4, {General tr
5**5 T1B-ker S€
Debl
ra\ eQ,*
p 3.At)$ -140n
Sornn S.Shq,3lu L'y,
DPrimary tr Run-Otf
{General tr Debl
q . tl. l6 7@,"0

o"l to,tb
g*#A ?Lo-tt LlPrimary
qpeneral
u
f
Run-off
Debt
$ log.y c

gPrimery tr Run-Off
0q tf""!rc frpereral tr Debt
rfu,.* t

sll trPdmary tr Run-Off

lt201
l,t
0u* Iv'f VBuiinos fCreneral D Debt
looo,e .

,7, trPrimarv tr Run-Off

bJ,o Ll*tkt Br-rwr fteenarir u oeot


l0 0 ,oo

uPrimary u Run-otl
081I SGeneral tr Debt
,+
,al
Val*-',n
b.5?o -
l*,<
OP.imary tr Run-Off
flGeneral tr Debt

LlF'nmary u HUn{/n
EcenerEl tl Debl

Subtotal of Contrlbutions This

Ark. Code Ann. S 7-S202 provides that a person \A,ho k.ts/vingly fails to comply with the provisions of subchapter 2 of cftapter 6, Title 7 of the Arkansas Code
shalt upon conviction be guitty of a Class A mi$demeanor.
REVISED O8i2O15

Tatum Complaint Exhibit 5, Page 4 of 8


ITEMIZED MONETARY CONTRIBUTIONS OVER $50
Please Tvpe or Print
Full Name and Maillng AddreBs of Contributor

l,lnt* Mt'Krs tleoovd t Xc€ner;t n q


oul^n
Artaaof
Debt
t,g+5
l,r +r rb in/rs[- trY b"Q,
trPdrnary tr Run€fi
trGeneral t-l Debt

trGen€ral tr Oebt

[Primary D Run-Off
trGeneral tr Debt

trGenerat [1 Debt

17. AL ITEMIZED MOI*ETARY CONTRIBUTIONS OVER


18. TOTAL NONITEMIZED MOIIIETARY C
{9. TOTAL IT,IOHETARY CONTRIBUTIONS THIS REPORT
(ineludes totels from lines l7 and t8) lv,+q5
Ark. Code Arn. S 7-S-202 provides lhat a person who knowingly fails to comply with the provisions of subchapler 2 of chapter 6, Tille 7 o{ the Arkansas Oode
rnisderneanol'
shall upon conviclion be guilty sf a class A
REVT'ED 0glz01s

Tatum Complaint Exhibit 5, Page 5 of 8


20. CAMPAIGN EXPENDITURES BY CATEGORY
Please Type or Print

CATEGORY TOTALAMOUNT

Television

Direct Mail

Returned Contributions

Paid CamnaiEn Workers

2I. TOTAL CAMPAIGN EXPENDITURES

22. PAID CAMPAIGN WORKERS


to w6rk on not have to be fulldme
NAME OF WORKER

23. TOTAL PAID CAMPAIGN WORKERS

Ark. Code Ann. S 7S-202 provides lhat a person who kno,vingly fails to comply wilh the provisicns oF subchapter 2 of ehapier 6. Tille 7 oI the Arkansas CodB
shall upon conviction be guilty of a Class,A misdemeanor.
REVISED O8I2O15

Tatum Complaint Exhibit 5, Page 6 of 8


24, ITEMIZED CAMPAIGN EXPENDITURES OVER $1OO
Please Type or Print
of this oaoe as
Name and Address ot

MllavlqLinEnth' ttl.-
P 0, w, 1?e+
'7gll i$$ { ryoc\,e

3 but 5ca1n1 rJ,$ oo,-*


Ir lr
\lo,*- g'#a
tl r /Wwr*t;l'n A ojast . a:
t t.
"Rnhcard"" J
Valequ 'l**n Tttts, Lhrnpat+, rr
?.o,tdA *utt;' Wowni".
la-. fiLtaao*
tAn,
phi,n
,-
P-A,boy -rr 0l '

25. TOTAL ITEMIZED EXPENDITURES THIS


28. TOTAL NCIT,IITEMIZEB EXPENDITURES THIS REPORT
27. TOTAL PAID CAMPAIGN WOR.KERS THI$ REPORT amount from line
28. TOTAL EXPENBITURES THIS REPORT {includes lines

NOTE: Exrenditures Reflected on Llnes,25, 26 and 27 Should F,-e-,,I-ptaled bv Galeqory in Sectien 20

Ark. C,cde Ann- S 7-6-202 provides that a person lvho knowingly fails to comply vrith the provisions of subchapter 2 of .hapter 6, Title 7 of the A*ansas Code
shall upon conviction be guilty of a Class A misdemeanor.
REVISED O8I2O15

Tatum Complaint Exhibit 5, Page 7 of 8


29. OUTSTANDING CAMPAIGH DEBTS
{including unpaid loans}
To Be Gompleted On Candidate's Final Report For An Election
Please Type or Print
Use addhbaal p€eres ff necassary

NAMEAND CURRENT BALANCE

30. TOTAL

A,t<. Code Ann. S 7-e202 provides that a person wtro knowingly fails to comply with lhe provisions of subchapler ? of chapter 6, Tiile 7 of tha Arkansas Code
shall upon convictiofl be guilty of a Cla$$ A misdemeanor.
REVISED O8I2O15

Tatum Complaint Exhibit 5, Page 8 of 8


City hall campaign bookkeeping: a fix on mayor's race, more study need... https://www.arktimes.com/ArkansasBlog/archives/2018/11/05/city-hall-...

6
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Arkansas Blog
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City hall campaign bookkeeping: a fix on mayor's race, more study needed on Ward 2
Posted By Max Brantley on Mon, Nov 5, 2018 at 8:06 AM

click to enlarge

MAYORAL MONEY: Warwick Sabin (center) has raised the most, but Baker Kurrus (right) has raised by far the most since
official fund-raising began June 1. Frank Scott has nearly matched Sabin in the official fund-raising period.

The Arkansas Democrat-Gazette today summarized campaign spending on races for Little Rock city board and mayor
and, in the process, fixed an earlier misunderstanding about the mayor's race but added to the fog about a city board
race.

* Mayor: Baker Kurrus has raised decisively more money than any other candidate since June 1, almost $325,000.
Warwick Sabin has reported more than $357,000 in total contributions, but more than $187,000 was transferred from
an exploratory committee that raised money before Kurrus entered the race and before official fund-raising began in
June. A Sabin campaigner disputed my original report that said just that and later apologized for saying he'd spoken
too soon. Frank Scott has raised almost $230,000 with more than $60,000 coming in his exploratory phase.

* City Board, Ward 2: The D-G article credited Valerie Tatum as having spent more than $43,000 while raising only
$13,495. The article explains the difference was made up by loans from the candidate and a relative and by her
exploratory fund-raising.

Those points are worth more examination. Tatum's most recent report, an amendment made after I pointed out
numerous discrepancies in the first filing, does not reflect a loan from the candidate. It does show a $6,500
contribution from her. It also reflects a loan from an uncle of $7,800. My reading of election law says loans are
allowable only from financial institutions and then must be reported as a loan to a candidate, not directly to the
campaign. Other loans must be considered as contributions and those are limited to $2,700. Her exploratory committee
effort? It raised only about $1,300 according to reports on file with the county clerk. That carryover, by the way, isn't
reported as a contribution to her regular campaign report, but it still falls far short of closing the gap in unaccounted for
money that Tatum has spent. Also, Tatum falls thousands short of identifying the $43,000 in expenditures, even
including exploratory committee spending.

Tatum had numerous bookkeeping problems while running the Covenant Keepers charter school, but they were
overlooked along with academic deficiencies by the state Board of Education in continuing the school's charter. The

Tatum Complaint Exhibit 6, Page 1 of 2

1 of 3 11/14/2018, 8:36 AM
City hall campaign bookkeeping: a fix on mayor's race, more study need... https://www.arktimes.com/ArkansasBlog/archives/2018/11/05/city-hall-...

Board tends to be more forgiving of charter schools than, say, the Little Rock School District.

Tatum, by the way, filed for Ward 2 from an address outside the ward, another error "corrected" after the city attorney
noted it. No lawsuit has been filed challenging her candidacy and none will be possible, the city attorney says, if she is
elected from the address to which she moved after filing closed. Ken Richardson is the incumbent in the race.
Tags: Little Rock mayor election, city board electoin, campaign fund-raising, Baker Kurrus, Warwick Sabin, Frank Scott, Valerie Tatum, Image

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Posted by Clayton J on 11/05/2018 at 8:51 AM

Posted by wannabee conservative on 11/05/2018 at 9:33 AM

Posted by mytwoscents on 11/06/2018 at 11:48 AM

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Tatum Complaint Exhibit 6, Page 2 of 2

2 of 3 11/14/2018, 8:36 AM
EXPLORATORY GOMMITTEE REGISTRATION FORM
NOTE: The exploratory committee registration form of a For assistance in completing
committee for an indir.tdual persofl who, upon becoming a this fotm contact:
candidate will seek a school district, township, municipal, or
county office, is required to be filed with the county cletk of the 7 Arkansas Ethics Commission
Post Office Box 1917
county in which the election will be held. The exploratory Little Rock, AR 7 2203-7917
committee registration form of a committee for an individual Phone (501) 324-9600
person who, upon becoming a catdidate will seek a state or Toll Frce (800) 422-7773
district office, is required to be filed with:

Mark Martin, Secretary of State irri, ,-tl-ij-i:,,:.i.il,-


I r...j.: --
,-:-._.) i.
-j I i : ;:i i l. -:
State Capitol, Room 026 Lar'i: i:r".=ii* ii.;i::.i;,i ii r:iii i t_i*i.iL
Little Rock, AR7220l
Phone (501) 682-5070
Fax (501) 682-3408
1. Provide the name,

Name of Committee:

Street Address: f.
State: zip coae: -7421*
2. Provide the name, title, address, and telephone number for each offacer:

a. Name: Title:
Address: City: State:_ Zip Code:

b. Name: Title: Telephone:


Address: City: State:_ Zip Code:

c. Name: Tifle: Telephone:


Address: City: State:_ Zip Code:

d. Name: Title: Telephone:


Address: City: State:_ Zip Code:

Provide the name, public office sought, telephone number, and address of the individual person who, upon bgcgming q _ -
candidate, is intended torreceive campaiglcontributions from the committee: 5Al.3ED*-+&
Nameor c"naia^t", VAlPitg n*,_.'1 ,, .r.r"onon rffi
Public Office Sought:

ooor""" city: V- state: AE- z.ecodel-7eA. l+


An exploratory commiftee is required to register within fifteen (15) days after receiving contributions during a calendar
yearwhich,intheaggregate,exceedfivehundred,cottaq($500)'
Affidavit
I certify under oath that the above information is true and correct.
Itf--
State of Arkansas
I )ss.
counry or Lm-!d&-z
d
4rtd
Subscribed and sworn before me this

Form Approved by the Arkansas Ethics Commission


Revised 08/09
Tatum Complaint Exhibit 7
Tatum Complaint Exhibit 8, Page 1 of 8
8
Tatum Complaint Exhibit 8, Page 2 of 8
Tatum Complaint Exhibit 8, Page 3 of 8
Tatum Complaint Exhibit 8, Page 4 of 8
Tatum Complaint Exhibit 8, Page 5 of 8
Tatum Complaint Exhibit 8, Page 6 of 8
Tatum Complaint Exhibit 8, Page 7 of 8
Tatum Complaint Exhibit 8, Page 8 of 8

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