texas ethics commission complaint concerning david glickler

10
Texas Ethics Commission RO. Box 12070 Austin, Texas 78711-2070 (512)463-5800 (TDD 1-800-735-2989) 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 complainant is required to attach to the complaint a copy of one of the following documents; complainants drivers license or personal laenimcaHon cenmcaie issuea unaer i.,napier a^l of the Transportation Code, or commercial driver's license issued under Chapter 522 of the Transportation Code; or a utility bill, bank statement, government check, paycheck or c=ther 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 filed. Effective September 1, 2009, an individual may aiso be eligibte to file a sworn compfaint with the Texas Ethics Commission if the individual owns real property in the state of Texas. Under this provision, the complainant will be required to attach to the complaint a copy of a property tax bill, notice of appraised value, or other government document that shows the name of the complainant, shows the address of the reai property in Texas, and identifies the complainant as the owner of the real property. OFFICE USE ONLY complainants drivers license or personal laenimcaHon cenmcaie issuea unaer i.,napier a^l of the Transportation Code, or commercial driver's license issued under Chapter 522 of the Transportation Code; or a utility bill, bank statement, government check, paycheck or c=ther 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 filed. Effective September 1, 2009, an individual may aiso be eligibte to file a sworn compfaint with the Texas Ethics Commission if the individual owns real property in the state of Texas. Under this provision, the complainant will be required to attach to the complaint a copy of a property tax bill, notice of appraised value, or other government document that shows the name of the complainant, shows the address of the reai property in Texas, and identifies the complainant as the owner of the real property. DocKel ,MumDe-!- complainants drivers license or personal laenimcaHon cenmcaie issuea unaer i.,napier a^l of the Transportation Code, or commercial driver's license issued under Chapter 522 of the Transportation Code; or a utility bill, bank statement, government check, paycheck or c=ther 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 filed. Effective September 1, 2009, an individual may aiso be eligibte to file a sworn compfaint with the Texas Ethics Commission if the individual owns real property in the state of Texas. Under this provision, the complainant will be required to attach to the complaint a copy of a property tax bill, notice of appraised value, or other government document that shows the name of the complainant, shows the address of the reai property in Texas, and identifies the complainant as the owner of the real property. .Dm's M.Hnd-dehvfered or Dale pQstm,^fked t. IDENTITY OF COMPLAINANT 1 COIV!Pl .,A !NANT NAME MS/MRS/MR i -SRST Mr. Adrian D NICKNAME LAST SUFFI.X Heath 2 COMPLAINANT PHYSICAL ADDRESS .A.nnRESS /\PT/SUITE*: cm, STATE, ZIP CODE 43 W. stony Bridge Court Spring TX 77381 (Fuil home or business address, including street, city, s*ate, and rip code) 3 COMPLAINANT MAILING ADDRESS ^ IcHeck if same as aJjovej 4 COMPLAINANT TELEPHONE NUMBER ADDRESS APT/SU(TE#; CITY STATE; ZiPCOOE (Full harm or busiiwss address, including street, city, stafe, arsdztp code) 3 COMPLAINANT MAILING ADDRESS ^ IcHeck if same as aJjovej 4 COMPLAINANT TELEPHONE NUMBER AREA CODE rnONK NUMBER EXT 832-978-1602 5 COMPLAINANT E -MAIL ADDRESS [email protected] II. IDENTITY OF RESPONDENT 6 RESPONDENT NAME MS/MRS /MR FIRST Ml Mr. David S NICKNAME 1 AST SUFFIX Glickler 7 RESPONDENT POSITION OR TITLE Candidate, District Judge District 22 8 RESPONDENT PHYSICAL .ADDRESS ADDRESS APT/SUITES; Cm. STATE; ZiPCOOE 153 Clifton Moore St Buda TX 78610 jFiill home or business address, inciuding street, city, i^tate. and zip codo) 9 RESPONDENT MAILING ADDRESS |j/J icmck if same as atiovej ADDRESS .APT/suite* CITY, STAi^; ZiP CODE (Foil home or bustness address,'mciud'mgstreet, city, state, and zip code) 10 RESPONDENT TELEPHONE NUMBER AREA CODE PHONE NUMBER EXT 512-475-4220 11 RESPONDENT E-MAIL ADDRESS (IF KNOWW) unknown GO TO PAGE 2 www.ethics.state.tx.us Revised 09/18/'2012

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Texas Ethics commission is investigating apparent violations of Texas election code and penal code outlined in this complaint including possible aggravated perjury - under Section 37.03 of the Texas Penal Code, making a false, material, perjurious statement during or in connection with an official Texas Ethics Commission proceeding constitutes aggravated perjury, a felony of the third degree.

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Page 1: Texas Ethics Commission complaint concerning David Glickler

Texas Ethics Commission RO. Box 12070 Austin, Texas 78711-2070 (512)463-5800 (TDD 1-800-735-2989)

S W O R N C O M P L A I N T BEFORE THE TEXAS ETHICS C O M M I S S I O N A n indiv idual must b e a resident of the state of Texas to b e el igible to file a sworn c o m p l a i n t w i th t h e Texas Ethics Commiss ion . The compla inant is required to attach to the compla in t a copy of one of the fo l lowing documents ;

• complainants drivers license or personal laenimcaHon cenmcaie issuea unaer i.,napier a^l of the Transportation Code, or commercial driver's license issued under Chapter 522 of the Transpor ta t i on C o d e ; or

• a utility bill, bank statement, government check, paycheck or c=ther 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 filed.

Effective September 1, 2009, an individual may aiso be eligibte to file a sworn compfaint with the Texas Ethics Commission if the individual owns real property in the state of Texas. Under this provision, t he comp la i nan t will be required to a t tach to the complaint a copy of a proper ty tax bi l l , notice of appraised value, or other government document that shows the name of the complainant, shows the address of the reai property in Texas, and ident i f ies the comp la inan t as the owner of the real property.

O F F I C E U S E O N L Y • complainants drivers license or personal laenimcaHon cenmcaie issuea unaer i.,napier a^l of the Transportation Code, or commercial driver's license issued under Chapter 522 of the Transpor ta t i on C o d e ; or

• a utility bill, bank statement, government check, paycheck or c=ther 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 filed.

Effective September 1, 2009, an individual may aiso be eligibte to file a sworn compfaint with the Texas Ethics Commission if the individual owns real property in the state of Texas. Under this provision, t he comp la i nan t will be required to a t tach to the complaint a copy of a proper ty tax bi l l , notice of appraised value, or other government document that shows the name of the complainant, shows the address of the reai property in Texas, and ident i f ies the comp la inan t as the owner of the real property.

DocKel ,MumDe-!-

• complainants drivers license or personal laenimcaHon cenmcaie issuea unaer i.,napier a^l of the Transportation Code, or commercial driver's license issued under Chapter 522 of the Transpor ta t i on C o d e ; or

• a utility bill, bank statement, government check, paycheck or c=ther 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 filed.

Effective September 1, 2009, an individual may aiso be eligibte to file a sworn compfaint with the Texas Ethics Commission if the individual owns real property in the state of Texas. Under this provision, t he comp la i nan t will be required to a t tach to the complaint a copy of a proper ty tax bi l l , notice of appraised value, or other government document that shows the name of the complainant, shows the address of the reai property in Texas, and ident i f ies the comp la inan t as the owner of the real property.

.Dm's M.Hnd-dehvfered or Dale pQstm,^fked

t. IDENTITY O F COMPLAINANT

1 COIV!Pl . ,A !NANT N A M E

MS/MRS/MR i-SRST

Mr. Adrian D NICKNAME LAST SUFFI.X

Heath

2 C O M P L A I N A N T P H Y S I C A L A D D R E S S

.A.nnRESS / \ P T / S U I T E * : cm, STATE, Z IP C O D E

43 W. stony Bridge Court Spring TX 77381 (Fuil home or business address, including street, city, s*ate, and rip code)

3 C O M P L A I N A N T M A I L I N G A D D R E S S

^ IcHeck if same as aJjovej

4 C O M P L A I N A N T T E L E P H O N E N U M B E R

A D D R E S S APT/SU(TE#; CITY STATE; ZiPCOOE

(Full harm or busiiwss address, including street, city, stafe, arsdztp code)

3 C O M P L A I N A N T M A I L I N G A D D R E S S

^ IcHeck if same as aJjovej

4 C O M P L A I N A N T T E L E P H O N E N U M B E R

AREA CODE rnONK NUMBER EXT

832-978-1602

5 C O M P L A I N A N T E - M A I L A D D R E S S [email protected]

II. IDENTITY OF R E S P O N D E N T

6 R E S P O N D E N T N A M E

M S / M R S / M R FIRST Ml

Mr. David S NICKNAME 1 AST SUFF IX

Glickler 7 R E S P O N D E N T

P O S I T I O N OR T ITLE

Candidate, District Judge District 22

8 R E S P O N D E N T P H Y S I C A L .ADDRESS

A D D R E S S A P T / S U I T E S ; Cm. STATE; ZiPCOOE

153 Clifton Moore St Buda TX 78610 jFiill home or business address, inciuding street, city, i^tate. and zip codo)

9 R E S P O N D E N T M A I L I N G A D D R E S S

|j/J icmck if same as atiovej

ADDRESS . A P T / s u i t e * CITY, STAi^; ZiP CODE

(Foil home or bustness address, 'mciud'mg street, city, state, and zip code)

1 0 R E S P O N D E N T T E L E P H O N E N U M B E R

AREA CODE PHONE NUMBER E X T

512-475-4220

11 R E S P O N D E N T E-MAIL A D D R E S S (IF KNOWW) unknown

GO TO PAGE 2

www.ethics.state.tx.us Revised 09/18/'2012

Page 2: Texas Ethics Commission complaint concerning David Glickler

Texas Ethics Commission P.O.Box12070 Austin. Texas 78711-2070 (512)463-5800 (TDD 1-800-735-2989)

lil. NATURE O F A L L E G E D VIOLATION Page 2 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) Title 15 of the Election Code; (2) Chapters 302,303,305,572,2004 of the Gov't Code; (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 file a financial statement with the commission; (5) § 2152.064 and § 2155.003 of the Gov't Code; (6) § 306.005 of the Gov't Code.

JC/OH Campaign Finance Report (Jan. 15) - 1/14/12

1) Reported an incorrect "Contribution Balance". After adjusting for in-kind contributions ($0.00) and expen­ditures made from personal funds ($17.77), the contribution balance should be $981.10, and not $1,834.80, as reported, in violation of Section 254.031(a)(8). Note that the candidate disclosed a contribution balance of $595.79 in the conrected July 2011 semiannual report filed on 7/07/11. In the alternative, if the contribution balance is correct, the officeholder failed to report additional political contributions and/or expenditures, in violation of Section 254.031.

2) Failed to disclose the contributor's principal occupation, job title, and/or employer/law firm (8 places), in violation of Section 254.0611.

8/30/11 $100.00 Caschera, Romeo (principal occupation?) 9/12/11 $250.00 Davis, Warren 10/14/11 $1,000.00 Green, Ricky Gob title?) 9/06/11 $100.00 Lee, Richard (principal occupation, job title?) 7/27/11 $250.00 Murray, Josh (principal occupation, job title?) 12/05/11 $100.00 Myers, Adrienne (Assistant Attorney General) 8/30/11 $100.00 Shell, Lon (principal occupation, job title?) 8/29/11 $55.00 Smith, Terry

3) Made a contribution to a political committee in connection with a primary election (3 places), in violation of Section 253.1611. (See the enclosed documents.)

9/30/11 $100.00 Cutler for Sheriff 9/27/11 $150.00 LULAC Council 4876 10/08/11 $40.00 LULAC Council 4876

4) Failed to disclose the actual vendor/company payee, address, date, and/or amount pertaining to the stated purpose of a poiiticai expenditure (3 places), in violation of Section 254.031(a)(3) and TEC rule 20.62.

11/03/11 $105.13 Glickler, Holly 11/10/11 $62.13 Glickler, Holly 11/18/11 $152.37 Glickler, Holly

5) Failed to fully disclose the purpose of a political expenditure (1 place), in violation of Section 254.031(a)(3). TEC rule 20.61 requires that the "purpose of expenditure" includes both the category of an expenditure and the description of the activity conducted with an expenditure. The description must include the specific item or service purchased, and make the reason for the expenditure clear. Expenditure de­scriptions which are vague, or which merely repeat the expenditure category, cleariy violate the rule, and suggest the unlawful conversion of campaign funds to personal use, in violation of Section 253.035.

11/25/11 $537.07 Home Depot (what specific items?)

JC/OH Campaign Finance Report (30th day) - 6/29/12, corrected

1) Reported an incorrect "Contribution Balance". After adjusting for in-kind contributions ($309.53), expendi­tures made from personal funds ($509.88), and credits ($60.00), the contribution balance should De $1,737.61, and not $596.20, as reported, in violation of Section 254.031 (a)(8). In the alternative, if the contri­bution balance is correct, the officeholder failed to report additional political contributions and/or

ATTACH ADDITIONAL P A G E S A S NEEDED

wwweth i cs - s ta te . t x . us Revised 09/18/2012

Page 3: Texas Ethics Commission complaint concerning David Glickler

Texas Ethics Commission P.O. Box 12070 Austin /rexas 78711-2070 (512)463-5800 (TDD 1-800-735-2989)

III. NATURE O F A L L E G E D VIOLATION Page 2 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) Title 15 of the Election Code; (2) Chapters 302,303,305,572,2004 of the Gov't Code; (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 file a financial statement with the commission; (5) § 2152.064 and § 2155.003 of the Gov't Code; (6) § 306.005 of the Gov't Code.

expenditures, in violation of Section 254.031.

2) Apparently accepted an in-kind political contribution from a corporation/labor union (1 place), in violation of Sections 253.003 and 253.094. Note that the candidate disclosed a Chili's (Chili's Grill & Bar) corporate contribution in his original 30th day campaign finance report filed on 4/24/12. In this corrected report, the candidate changed the name of contributor to the corporation's manager Mark Felch. However, records obtained from the Texas Ethics Commission show that the contributor address is actually that of Chili's Grill & Bar. (See the enclosed documents.) As such, a reasonable person could easily conclude that the candidate accepted an illegal corporate contribution for his campaign.

4/01/12 $59.53 Chili's (4/24/12 report) 4/01/12 $59.53 Felch, Mark (6/29/12 report)

3) Failed to disclose the contributor's principal occupation, job title, and/or employer/law firm (16 places), in violation of Section 254.0611.

4/09/12 $200.00 Carter, Stuart 2/17/12 $60.00 Cole, Keith Jr Gob title?) 4/09/12 $100.00 Crowell, David (principal occupation?) 4/01/12 $59.53 Felch, Mark (principal occupation?) 2/02/12 $250.00 Goodwin, Grant Gob title?) 4/01/12 $100.00 Hofeldt, Tiffany Gob title?) 1/29/12 $100.00 Martin, Stanley Gob title?) 3/21/12 $100.00 Moncure, John (principal occupation?) 4/09/12 $70.00 Pacheco, John (principal occupation, job title?) 1/11/12 $100.00 Rehmet, Patrick Gob title?) 2/17/12 $250.00 Sergi, David Gob title?) 3/27/12 $500.00 Stapleton, Michael (principal occupation?) 3/21/12 $75.00 Varjabedian, Annen (principal occupation?) 4/01/12 $250.00 Wallace, Trey (principal occupation?) 4/01/12 $75.00 Wallace, Trey (principal occupation?) 4/09/12 $250.00 Weber, Andrew (principal occupation?)

4) Made a contribution to a political committee in connection with a primary election (1 place), in violation of Section 253.1611.

1/28/12 $245.00 HaysG.O.R

5) Failed to fully disclose the address of person or entity receiving a political expenditure (1 place), in viola­tion of Section 254.031 (a)(3).

1/28/12 $245.00 HaysG.O.R

JC/OH Campaign Finance Report (8th day) - 6/25/12, corrected

1) Reported an incorrect "Contribution Balance". After adjusting for in-kind contributions ($234.45) and expenditures made from personal funds ($688.95), the contribution balance should be $1,905.62, and not $1,494.12, as reported, in violation of Section 254.031(a)(8). In the alternative, if the contribution balance is correct, the officeholder failed to report additional political contributions and/or expenditures, in violation of Section 254.031.

ATTACH ADDITIONAL P A G E S A S NEEDED

www,ethics.state.tx us Revised 09/18/2012

Page 4: Texas Ethics Commission complaint concerning David Glickler

Texas Ethics Commission P.O-Box12070 Austin, Texas 78711-2070 (512) 463-5800 (TDD 1-800-735-2989)

III. NATURE OF A L L E G E D VIOLATION Page 2 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) Title 15 of the Election Code; (2) Chapters 302,303,305,572,2004 of the Gov't Code; (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 file a financial statement with the commission; (5) § 2152.064 and § 2155.003 of tTte Gov't Code; (6) § 306.005 of the Gov't Code.

2) Failed to disclose the contributor's principal occupation, job title, and/or employer/law firm (7 places), in violation of Section 254.0611.

4/25/12 $1,000.00 Bolton, Ed (principal occupation?) 5/05/12 $70.00 Bolton, Ed (principal occupation?) 5/15/12 $100.00 Butler, Robert 5/14/12 $75.00 Cole, Keith Jr (principal occupation, job title?) 5/18/12 $250.00 Hancock, J.R. Gob title?) 5/03/12 $400,00 Lopez, Ruben Gob title?) 5/08/12 $100.00 Miller, William 11 Gob title?)

JC/OH Campaign Finance Report (July 15) - 7/15/12

1) Reported an incorrect "Contribution Balance". After adjusting for in-kind contributions ($314.00) and expenditures made from personal funds ($0.00). the contribution balance should be $2,591.88, and not $1,713.54, as reported, in violation of Section 254.031(a)(8). In the alternative, if the contribution balance is correct, the officeholder failed to report additional political contributions and/or expenditures, in violation of Section 254.031. 2) Failed to disclose the contributor's principal occupation, job title, and/or employer/law firm (8 places), in violation of Section 254.0611.

6/08/12 $800.00 Carter, Stuart (principal occupation, job title?) 5/23/12 $500.00 Hill, Matthew Gob title?) 5/21/12 $260.00 Jones, Gina Gob title?) 6/21/12 $500.00 Matthews, Guy E. (job title?) 6/23/12 $100.00 Carter, Stuart (principal occupation, job title?) 5/31/12 $100.00 Mullen, Shawn (principal occupation?) 5/31/12 $500.00 Sergi, David (job title?) 6/04/12 $100.00 Womble, Rick Gob title?)

JC/OH Campaign Finance Report (Runoff) 7/22/12

1) Reported an incorrect "Contribution Balance". After adjusting for in-kind contributions ($90.00) and ex­penditures made from personal funds ($0.00), the contribution balance should be $6,299.84, and not $5,636 47, as reported, in violation of Section 254.031(a)(8). In the alternative, if the contribution balance is correct, the officeholder failed to report additional political contributions and/or expenditures, in violation of Section 254.031.

2) Failed to disclose the contributor's principal occupation, job title, and/or employer/law firm (11 places), in violation of Section 254.0611.

7/09/12 $100.00 Beard, Marvin (principal occupation?) 7/14/12 $100.00 Clarke, Ed (principal occupation?) 7/06/12 $100.00 Crowell. David Gob title?) 7/18/12 $100.00 Kinney. E. Waliy (principal occupation?) 7/09/12 $250.00 Kolodzey, JB (job title?) 7/09/12 $100.00 Paul, Mary Pat (principal occupation?)

ATTACH ADDITIONAL P A G E S A S NEEDED

ww»«. ef hies, s ta te , tx _ us RevLsed 09/18/2012

Page 5: Texas Ethics Commission complaint concerning David Glickler

Texas Ethics Commission P.O. Box 12070 Austin, Texas 78711-2070 (512)463-5800 (TDD 1-800-735-2989)

III. NATURE O F A L L E G E D VIOLATION Page 2 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) Title 15 of the Election Code; (2) Chapters 302, 303.305,572,2004 of the Gov't Code; (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 file a financial statement with the commission: (5) § 2152.064 and § 2155.003 of the Gov't Code; (6) § 306.005 of the Gov't Code.

7/09/12 7/09/12 7/18/12 7/18/12 7/09/12

$100.00 $60.00 $2,000.00 $1,000.00 $200.00

Powers, Jim Russian, Joe Seale, Hank Seale, Lyssa Spracklen, Paul

(principal occupation, job title?) (principal occupation?) (job title?) (job title?) (principal occupation?)

3) Failed to disclose the actual vendor/company payee, address, date, and/or amount pertaining to the stated purpose of a political expenditure (2 places), in violation of Section 254.031(a)(3) and TEC rule 20.62.

7/09/12 $170.17 Coffee, Jeff 7/09/12 $108.30 Spracklen, Elizabeth

JC/OH Campaign Finance Report (Final) - 12/11/12

1) Reported an incorrect 'Contribution Balance". After adjusting for in-kind contributions ($0.00) and expen­ditures made from personal funds ($500.00), the contribution balance should be $6,251.41, and not $0.00, as reported, in violation of Section 254.031(a)(8). In the alternative, if the contribution balance is correct, the officeholder failed to report additional political contributions and/or expenditures, in violation of Section 254.031.

2) Made aggregated contributions exceeding $100 in a calendar year to a candidate/officeholder, in violation of Section 253.1611. Note ttiat in-kind political contributions were made to Texas Representative Jason Issac.

9/21/12 $184.30 HEB ... Campaign Event with Jason Issac 9/21/12 $40.00 Wild Flower Cakery ... Campaign Event with Jason Issac

ATTACH ADDITIONAL P A G E S A S NEEDED

www.eth ics -s ta te . tx .us Revised 09/18/2012

Page 6: Texas Ethics Commission complaint concerning David Glickler

Texas Ethics Commission P.O. Box 12070 Austin. Texas 78711-2070 (512)463-5800 (TDD 1-800-735-2989)

IV. STATEMENT O F F A C T S Page 3 State the facts constituting the alleged violation(s), including the dates on which or the period of time in which the alleged violation(s) occurred. Identify allegations of fact not personally known to the complainant, but alleged on information and belief. Please use simple, conc ise , and direct statements.

As a public official, Mr. David Glickler knows the importance of following the law when dealing with the tax­payers' public funds. He must also know that the same concerns apply when dealing with political campaign funds. Over the last two years, Mr. Glickler apparently accepted a corporate/labor union contribu­tion, made unlawful contributions to candidates/officeholders and political committees, failed to fully disclose contributors' principal occupations, job titles, and/or employers/law firms, failed to fully disclose the recipients and purposes of political expenditures, and filed several otherwise incomplete reports, with contribution balances indicating undisclosed campaign contributions and/or expenditures. Note that the final report, signed by Mr. Glickler under penalty of perjury, shows a serious contribution balance discrep­ancy of $6,251.41. This discrepancy implies that Mr. Glickler personally retained unexpended political contributions, in spite of his signed statement to the contrary.

Knowingly accepting a corporate/labor organization political contribution is a third-degree felony offense, with a statute of limitations of three years. In addition, a violation of Section 253.1611 subjects Mr. Glickler to a civil penalty of up to three times the illegal contribution amount. Also, if Mr. Glickler converted political contributions to personal use, he would be civilly liable to the state for the converted amount plus reason­able court costs. In any case, Mr. Glickler signed his campaign finance reports under the penalty of perjury, and bears the responsibility of checking the report accuracy and fully disclosing the information required by state law.

Mr. Glickler should also be aware that, under Section 37.03 of the Texas Penal Code, making a false, mate­rial, perjurious statement during or in connection with an official Texas Ethics Commission proceeding constitutes aggravated perjury, a felony of the third degree.

ATTACH ADDITIONAL P A G E S A S NEEDED

www.eth ics .staie. tx us Revised 09/18/2012

Page 7: Texas Ethics Commission complaint concerning David Glickler

Texas Ethics Commission P.O. Box 12070 Austin, Texas 78711-2070 (512)463-5800 (TDD 1-800-735-2989)

V. LISTING O F DOCUMENTS AND O T H E R MATERIALS Page 4 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.

Campaign Finance Reports (selected pages) -7/07/11 (July'11), con-ected 1/14/12 (Jan.'12) 6/29/12 (30th day), corrected 6/25/12 (8th day), corrected 7/15/12 (July'12) 7/22/12 (Runoff) 12/11/12 (Final)

Information on corporate contributor Chili's Grill & Bar; Brinker International, Inc.

information on candidates/officeholders -Hays County Sheriff Gary Cutler Texas Representative Jason Issac

ATTACH ADDITIONAL P A G E S A S NEEDED

www.e th ics .s ta te . tx .us Revised 0 9 / i e / 2 0 i ;

Page 8: Texas Ethics Commission complaint concerning David Glickler

Texas EtNcs Commission P.O. Box 12070 Austin, Texas 78711-2070 (512)463-5800 (TDD 1-800-735-2989)

VI. AFFIDAVIT BASED ON PERSONAL KNOWLEDGE

(Execute this affidavit if the acts a t leged are within your direct personal knowledge.)

Pages

I. , complainant,

swear that I am a resident of the state of Texas, i swear that I have knowledge of the

facts alleged in this cxjmpiaint and (hat the information contained in Shis compiamt is

true; and correct.

Signature at Complainant

.AFFIX NOTARY STAMP SEAL ABOVE

Sworn to and subscribed before me, by the s a i d . this the c!av of

20 ., to certify v,'ti!cn, witness my isand and s e a ! of office.

Signature of otTicer administering oath Printed nafTse of officer administering oatfi Title of officer administering oath

VII. AFFIDAVIT BASED ON INFORMATION AND BELIEF

(Execu te t t i is a f f i dav i t if t he ac ts a l l eged are n o t w i t t i i n y o u r d i r e c t pe r sona l k n o w t e d g e , b u t are based o n reasonab le be l ie f , )

, . corTipiainant.

swear that I am a resident of the state of Texas ! swear that 1 have reason to believe

and do believe that the violation alleged m this complatnt has occurred. The source

of my information and belief is Campaign Finance Reports.

Signature of Complanant

AFF IX NOTARY .r.IA^!P t S C A t A B O V E

Sv/oiTi to and subscribed before me, by tl^e said A d v i c > \'

20 , to certify wh ich , w i tness mv hand a n d sea l cf office.

iiignature of officer adrniniste.nng oatti Printed name of officer administering oatSi

th is the — d a y of

a n d sea l cf office.

TiUe of officer administering oath

www ethics,state tx us Revised 09/18/2012

Page 9: Texas Ethics Commission complaint concerning David Glickler

Texas Ethics Ccmmission P.O. Box 12070 Austin, Texas 78711-2070 (512)463-5800 TDD 1-800-735-2989

r \CAL CONTRIBUTIONS ^ THAN PLEDGES OR LOANS (JUDICIAL)

S C H E D U L E A

>

The 1 NSTRUCTION GUIDE explains how to complete this forni. 1 PAGES

Schedule: 3/16 Report: 6/35

2 FSLER NAME Glickier, David S. (Mr.) 3 ACCOUHT# (Ethics Commission fiiers)

00067433

4 Date I 5 Fuii name of cantributor • outnaf-state PAC (SD#_ Fetch, Mark

7 Amount of | 8 in-kind contribution contribution ($ ) . description (if applicable)

Food for Campaign Event

04/01/2012 6 Co.ntnbutor address; City; State; Zip Code

Buda, TX 78610

$59.53

{if travel outside of Texas, complete Schedule T) Q

9 Contributor's f rincipai occupation 1© Contributor's job titie yanager

11 Coninbutor's empioyer / law f m Chiii's

1 2 Lav̂ Srm of contributor's spouse (if any)

13 If contributor is a child, law rirm of parent(s) (if any)

Date

02/02/2012

Full name of contributor F} out-of-state PAC (!D# )

Goodwin, Grant Amount of | In-kind contribution

contribution ($) , description (if applicable)

$250.00 1

1

(If travel outside of Texas, QO~x::sts Ssheduie T| Q

Date

02/02/2012 Contributor address; City; State; Zip Code

Aus t in , T X 78736

Amount of | In-kind contribution contribution ($) , description (if applicable)

$250.00 1

1

(If travel outside of Texas, QO~x::sts Ssheduie T| Q

Contributor's principal ccoupaticn j Contributor's job title Attorney j

i Contributor's employer / law firm ! taw f:rm of contributor's spouse (if any) Texas Yosjth Commission |

If contributor is a child, law firm of parent(s) (if any)

Date

03/26/2012

Full name of contributor f l out-of-state PAC (ID# 5

Grossberg, Dan Amount of | In-kind contribution

contribution ($) ^ description (if applicable)

$50.00 j

1

pf travel outsits of Taxes, ss.Tipfeis Sxksdaie Tj Q

Date

03/26/2012 Contributor address; City; Stats; Zip Code

Gai thersburg . M D 20878-4724

Amount of | In-kind contribution contribution ($) ^ description (if applicable)

$50.00 j

1

pf travel outsits of Taxes, ss.Tipfeis Sxksdaie Tj Q

Contributor's principal occupation Accoun tan t

Contributor's job title

Contributor's empioyer / iaw firm Ernst & Young

Law nrrri of contributor's spouse (if any)

if contributor is a child, law firm of parent(s) (if any)

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Page 10: Texas Ethics Commission complaint concerning David Glickler

Texas Ethics Commission P.O. Box 12070 Austin, Texas 78711-2070 (512)463-5800 TDD 1-800-735-2989

POLITICAL CONTRIBUTIONS SCHEDULE A (J) OTHER THAN PLEDGES OR LOANS (JUDICIAL)

The 1 NSTRUCTION GUIDE explains how to complete this form. 1 PAGE #

Schedule: 3/16 Report: 6/35

2 FILER NAME Glicl<ler, David S. (Mr.) 3 ACCOUNT* (Ethics Commission filers)

0 0 0 6 7 4 3 3

4 Date

0 4 / 0 1 / 2 0 1 2

5 Full name of contributor • out-of-state PAC flD# )

Felch, Mark

7 Amount of | 8 In-kind contribution contribution ($) . description (if applicable)

Food for Campaign Event

$ 5 9 . 5 3 1

1

(If travel outside of Texas, complete Schedule T) | |

4 Date

0 4 / 0 1 / 2 0 1 2 6 Contributor address; City; State; Zip Code 420 Old San Antonio Road Buda, TX 78610

7 Amount of | 8 In-kind contribution contribution ($) . description (if applicable)

Food for Campaign Event

$ 5 9 . 5 3 1

1

(If travel outside of Texas, complete Schedule T) | |

9 Contributor's principal occupation 10 Contributor's job title Manager

11 Contributor's employer / law firm Chili 's

12 Law firm of contributor's spouse (if any)

13 If contributor is a child, law firm of parent(s) (if any)

Date

0 2 / 0 2 / 2 0 1 2

Full name of contributor D out-of-state PAC (ID# )

Goodwin, Grant

Amount of | In-kind contribution contribution ($) . description (if applicable)

$ 2 5 0 . 0 0

(If travel outside of Texas, complete Schedule T) | |

Date

0 2 / 0 2 / 2 0 1 2 Contributor address; City; State; Zip Code 9856 Weir Loop Aust in , TX 78736

Amount of | In-kind contribution contribution ($) . description (if applicable)

$ 2 5 0 . 0 0

(If travel outside of Texas, complete Schedule T) | |

Contributor's principal occupation Attorney

Contributor's job title

Contributor's employer / law firm Texas Youth Commiss ion

Law firm of contributor's spouse (if any)

If contributor is a child, law firm of parent(s) (if any)

Date

0 3 / 2 6 / 2 0 1 2

Full name of contributor ("1 out-of-state PAC (ID# )

Grossberg, Dan

Amount of | In-kind contribution contribution ($) . description (if applicable)

$ 5 0 . 0 0

(If travel outside of Texas, complete Schedule T)

Date

0 3 / 2 6 / 2 0 1 2 Contributor address; City; State; Zip Code 12221 Quince Valley Gai thersburg, MD 20878-4724

Amount of | In-kind contribution contribution ($) . description (if applicable)

$ 5 0 . 0 0

(If travel outside of Texas, complete Schedule T)

Contributor's principal occupation Accountant

Contributor's job title

Contributor's employer / law firm Ernst & Young

Law firm of contributor's spouse (if any)

If contributor is a child, law firm of parent(s) (if any)

Etectronicaliy filed using Web Filer Version 1.6