SOUTH CAROLINA LAW ENFORCEMENT DIVISION

NIKKI R. HALEY

MARK A. KEEL

Governor

Chief

December 5, 2013
INVESTIGATIVE REPORT

TO:

File 32-13-0019

FROM:

Lieutenant Kevin W. Baker
Lieutenant Michael Greene
Lieutenant Brian Bolchoz
Senior Special Agent David Williams

RE:

Public Corruption / Official Misconduct
Robert W. Harrell, Jr. (subject)
State of South Carolina (victim)

COUNTY:

Richland

Introduction
On February 14, 2013, the South Carolina Law Enforcement Division (SLED) received a letter
of request (Attachment 1) from Chief Deputy Attorney General John W. McIntosh with the SC
Office of the Attorney General (OAG) to conduct a preliminary criminal inquiry involving the
Speaker of the SC House of Representatives, Robert W. “Bobby” Harrell. The OAG requested
an inquiry based on a letter of complaint (Attachment 2) from E. Ashley Landess, which
questioned Speaker Harrell’s conduct. On February 19, 2013, SLED Captain (Capt.) T.
Robertson assigned Lieutenant (Lt.) Kevin W. Baker to conduct an investigation.

An Accredited Law Enforcement Agency
P.O. Box 21398 / Columbia, South Carolina 29221-1398 / (803) 737-9000 / Fax (803) 896-7588

 File 32-13-0019
Page 2
Summary
Lt. Baker, along with SLED Lt. Michael Greene, Lt. Brian Bolchoz, and SS/A David Williams,
reviewed the complaint from E. Ashley Landess, President of the South Carolina Policy Council
(SCPC). Her complaint states, “The South Carolina Policy Council (“SCPC”) – along with
multiple citizens, organizations and South Carolina journalists – has publicly raised serious, valid
and documented concerns that the Speaker of the House Robert Harrell, Jr. has engaged and may
continue to engage in an ongoing pattern of abuse of power that appears to violate multiple South
Carolina ethics laws.”

Landess listed the following concerning:
1. “If Robert Harrell used his office for his own financial benefit and that of his family
business, he may have violated South Carolina law.”
2. “Robert Harrell seems to have broken the law by using campaign funds for personal
purposes.”
3. “Robert Harrell’s appointment of his brother to a position on the Judicial Merit Selection
Commission seems to be against South Carolina law.”
4. “Robert Harrell has publicly stated that he failed to maintain certain records to document
his expenditures. State law requires candidates to maintain such records for four years.”
5. “Robert Harrell did not adequately itemize reimbursements to himself from his campaign
account as the law requires.”

Landess based her complaints on SC Code of Laws Title 8 Chapter 13, which covers Ethics,
Government Accountability, and Campaign Reform.

In Memorandums of Interview (MOIs) (Attachment 3) conducted by SLED Agents, Landess
also voiced concerns over Speaker Harrell’s connection to and possible benefit from the
Palmetto Leadership Council (PLC), a non-candidate committee or Political Action Committee
(PAC), based in SC.

Upon examination of these complaints, SLED Agents conducted interviews, collected
documents, reviewed records, and prepared MOIs in relation to this investigation. Due to the

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complex and detailed information involved in this investigation, the topics under investigation
will be discussed in the following sections:

Section 1:

Speaker Harrell’s appointment of his brother, John Davis Harrell, to the Judicial
Merit Selection Commission (JMSC)

Section 2:

Speaker Harrell’s contact with the SC Board of Pharmacy concerning his personal
business, Palmetto State Pharmaceuticals

Section 3:

Speaker Harrell’s documentation of campaign fund usage

Section 4:

Speaker Harrell’s campaign reimbursements for use of his personal aircraft

Section 5:

Speaker Harrell’s campaign fund usage

Section 1:
Speaker Harrell’s appointment of his brother, John Harrell, to the JMSC
In Landess’ complaint filed with the OAG, she referenced § 8-13-750. SECTION 8 13 750: “No
public official, public member, or public employee may cause the employment, appointment,
promotion, transfer, or advancement of a family member to a state or local office or position in
which the public official, public member, or public employee supervises or manages.”

The investigation revealed the following information:


Robert W. Harrell has been the Speaker of the SC House of Representatives since 2006.



SC Code of Laws § 2-19-10 defines the JMSC’s appointments, qualifications and term.
Section 2-19-10 states that the JMSC is composed of ten members, of which five are
appointed by the Speaker of the House. Of these five, three members must be serving
members of the General Assembly, and two members must be selected from the general
public. “The term of office of a member of the commission who is not a member of the
General Assembly shall be for four years subject to a right of removal at any time by the
person appointing him, and until his successor is appointed and qualifies.”

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

In a memorandum (Attachment 4) dated March 15, 2007, Jane O. Shuler, Chief Counsel
of the JMSC, announced “that on March 9, 2007, the Speaker of the House, Bobby
Harrell, appointed attorneys John Davis Harrell of Charleston and Donald H. Sellers of
Greenville to the Commission as the public members.”



In letters (Attachment 5) dated July 19, 2007, and February 20, 2008, to Secretary of
State Mark Hammond, Shuler listed John Davis Harrell as a member of the JMSC.



On August 13, 2013, Lt. Baker and Lt. Bolchoz interviewed Speaker Harrell and an MOI
(Attachment 6) was prepared, which provided the following information: Speaker
Harrell did appoint his brother to the JMSC. When he appointed his brother, he was
aware of SC Code § 8-13-750. He does not believe he supervises or manages his
brother’s position on the JMSC. He believes the Chairman of the JMSC oversees the
management of commission members. He could not remember who has the authority to
discipline JMSC members.



Former JMSC Chairman F. G. “Greg” Delleney, Jr. provided Speaker Harrell with a
letter (Attachment 7) which provided the following information: he has “never been
supervised or managed by the Speaker of the House. In fact, the Chairman supervises
and manages the Commission.” Delleney did note that the Speaker appoints the House
members of the JMSC.

Section 2:
Speaker Harrell’s contact with the SC Board of Pharmacy concerning his
personal business, Palmetto State Pharmaceuticals (PSP)
In the SCPC complaint (Ref. Att. 2) filed with the OAG, Landess referenced SC Code § 8-13700, which states that a public official cannot use their position in office for financial gain. She
specifically discussed the following instances: Speaker Harrell’s input in the application process
for PSP at the SC Board of Pharmacy (BOP), a Division of the SC Department of Labor,
Licensing, and Regulation (LLR); and his letter to SC hospitals soliciting business for PSP which
referenced his position as Speaker of the House.

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The investigation revealed the following information:
1. Speaker Harrell’s input in the application process for PSP at the SC Board of Pharmacy.

Documents in the SCPC Complaint (Ref Att 2) contained the following points:
 PSP’s application for a “New non-dispensing Drug Outlet Permit Application”
was sent using an “Office of the Speaker” SC House of Representatives
envelope.
 On the envelope, a handwritten note stating, “May 2, 2006, We would appreciate
your urgent attention to this request. Bobby Harrell”
 The application was sent by FedEx and was marked received by the SC Board of
Pharmacy on May 3, 2006.
 The “Date of Expected Opening” on the application was listed as May 15, 2006.
 At the bottom of the application, it states, “Your completed application along with
the $200.00 new permit fee must be received in the Board office at least fortyfive (45) days before the required permit is needed.”
 A handwritten note from BOP employee, Sheila Young, to BOP employee, Clelia
Sanders, states, “Monte Templeton, the R.Ph will be in contact with you about
this facility. It needs to be done ASAP after Monte calls, per Mr. Bryant because
this is the speaker of the house. SY.”
 Emails between Board of Pharmacy employees suggested Speaker Harrell and his
staff were upset with the time it was taking to get the permit.
 Speaker Harrell held a meeting in his House Office with BOP employees, Lee
Ann Bundrick and Clelia Sanders, and BOP Chairman Robert Bradham was in
attendance by telephone. This meeting was held to discuss the application
process.

On June 3, 2013, Don Hottel, former Chief of Staff for Speaker Harrell, was interviewed and an
MOI (Attachment 8) was prepared, which provided the following information: Hottel called
employees at the BOP to find out what steps needed to be taken by Speaker Harrell’s company to
get their permit like any other business. This call was made at the request of Speaker Harrell.

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Hottel made this call as he would for any other constituent or citizen of the State. He did not
remember the name of the person he spoke with at LLR and was not upset with them. He did not
ask for any special privileges because the business belonged to the Speaker. He asked the
person, “for any other business, what is the next step?”
In Speaker Harrell’s interview (Ref Att 6), he provided the following information: Speaker
Harrell did speak with employees at the BOP about PSP. He believed he spoke to the Executive
Director of the BOP, to Sharon Dantzler (BOP attorney), and to Bobby Bradham, who was the
1st Congressional District member on the BOP. He called them to find out what the process was
to license a company like PSP. He did not ask anyone at the BOP to give special treatment to
PSP’s application process. He did not use his position as Speaker of the House to influence
employees or members of the BOP in their decisions on the PSP application process, and he did
not use his public office to influence the BOP employees or members to gain an economic
interest for PSP. Speaker Harrell does not remember if he had a meeting with BOP employees at
his office on State House grounds. When asked if the PSP application was moved in front of
other applications at the BOP at his request, Speaker Harrell responded, “I don’t think so.”

On March 5, 2013, Lt. Baker and Lt. Greene interviewed Lee Ann Bundrick, Administrator of
the SC BOP, and prepared an MOI (Attachment 9), which provided the following information:
Chairman Bradham set up the meeting. She, along with LLR employee Clelia Sanders, went to
the Speaker’s Office at the State House, and she, Sanders, and the Speaker had a telephone
conference with Chairman Bradham. The Speaker asked about the required paperwork from the
US Food & Drug Administration (FDA) and other operational-type questions concerning the
business. She did not consider this meeting unusual. She had, in the past, met with individuals
(owners, pharmacists, managers) from other companies trying to get questions answered about
the application and inspection process. She did not believe the application or the inspection
process for PSP was handled any differently than any other case. She did not believe it was sped
up or handled any differently because the owner was the Speaker of the House, Bobby Harrell.

On April 18, 2013, Lt. Brian Bolchoz and SS/A David Williams interviewed Clelia Sanders and
prepared an MOI (Attachment 10), which provided the following information: she was assigned

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as the inspector handling PSP’s application process. PSP applied for a “non-dispensing drug
outlet permit” as a drug repackaging company. Because of this type of business, PSP was told
the company would need a US FDA registration and that no SC permits or licenses could be
issued until the FDA registration was obtained. At her first inspection of PSP, she met with
Speaker Harrell, David Grimm, the Speaker’s son (Trey Harrell), and Monte Templeton, the
pharmacist consultant. She explained the process to them and what needed to be done. After the
inspection, she received several calls from the Speaker and Grimm on the status of the process.
She provided them with information on what else needed to be done or she advised them to
submit, in writing, verification of the things accomplished. Eventually, she stopped taking the
calls.
Sanders remembered attending a meeting in Speaker Harrell’s office on the State House grounds.
Bundrick was with her at the meeting and Bradham was conferenced into the meeting by
telephone. Sanders had spoken to owners and to high-level employees of companies by
telephone before but she had never been in a face-to-face meeting with an owner. She thought it
was very unusual. Speaker Harrell told them that he was very busy, so this is why he held the
meeting in his office rather than somewhere else. He had several statutes from the SC Code of
Laws that he had printed and was questioning every statute and why the process had to be
handled the way it was being done. Speaker Harrell had a big issue with the physician
dispensing law. Sanders explained why things had to be done the way they were and told him
there was no way to go around the laws as they were written.

Sanders did remember seeing the note from BOP Compliance Officer Sheila Young. She did not
remember being handed the note and believed it was left in her box. She was never given
specific instructions by anyone to handle the PSP application any differently than any other
application. She always handled applications in the order she received them, and she never
moved anyone to the top of the list.
On April 8, 2013, Lt. Brian Bolchoz and SS/A David Williams interviewed Robert “Bobby”
Bradham, former Chairman of the SC BOP, and prepared an MOI (Attachment 11), which
provided the following information: he received a call from Speaker Harrell about PSP and later

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was on a conference call with Speaker Harrell, Lee Ann Bundrick, and someone else he could
not remember. Speaker Harrell had questions about the application process and the need for a
license from the US FDA. Speaker Harrell and PSP complied with every aspect of the
inspection, licensing, and permitting process. There was never any pressure or influence on the
BOP, by anyone from LLR, Speaker Harrell, or anyone else, to handle the PSP permit and
licensing request any differently than any other request.

After the meeting with Speaker Harrell, Bradham did send an email to Bundrick in which he
expressed his concern that the application for PSP was being handled differently because the
business belonged to Speaker Harrell. This was his personal opinion, and he based this on the
fact that he had never met with a business owner during his time on the BOP. The meeting with
Speaker Harrell was unusual and made the situation different as far as he was concerned.

On March 6, 2013, Lt. Baker and Lt. Greene interviewed Randall Bryant, a former Deputy
Director at LLR, and prepared an MOI (Attachment 12), which provided the following
information: Bryant was shown the handwritten note from Young to Sanders. Bryant never saw
this note before, and he did not remember a telephone call with Young. However, he may have
called her about it and not remembered. He indicated that he would have paid attention to a
request from the Speaker to make sure it was assigned and being handled. He would not put the
Speaker’s permit application ahead of anyone else’s application. Furthermore, he would not
condone anybody putting a case like this ahead of another case. Neither the Speaker nor anyone
from the Speaker’s Office called or contacted Bryant for any preferential treatment.

On April 3, 2013, Lt. Baker and Capt. Robertson interviewed Sheila Young, former Compliance
Manager at BOP, and prepared an MOI (Attachment 13), which provided the following
information: Young was shown a handwritten note. She advised the note was in her
handwriting, and she recalled that she had a conversation with Randy Bryant, Assistant Deputy
Director of LLR, in which he told her to get this inspection done ASAP because it was Speaker
Harrell’s company. Bryant did not say he had spoken with Speaker Harrell or anyone from his
office, but Bryant did tell her to get it done as soon as possible. He wanted it done ASAP
because the company belonged to Speaker Harrell.

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She never spoke to Speaker Harrell or anyone from his staff about the inspection. She did not
speak with anyone from the House of Representatives concerning the inspection. The inspection
process for PSP did receive faster service because her supervisor, Randy Bryant, requested it be
done “ASAP”, and not because she received any special requests from Speaker Harrell or his
office.

Young pointed out that even though the inspection received faster service, it did not receive any
leniency on passing the inspection process. If there had been an issue with the inspection, the
issue would have had to be corrected before the company passed inspection just like any other
company.
2. Speaker Harrell’s solicitation letter to SC hospitals

Documents in the SCPC Complaint (Ref Att 2) contained the following points:


Speaker Harrell sent a letter to SC hospitals to solicit business for PSP.



Speaker Harrell mentioned his position as Speaker of the SC House of Representatives.



Hospital administrators contacted the BOP about their concerns regarding the letter.



LLR Attorney Sharon Dantzler advised the BOP not to give advice on the letter, because
Speaker Harrell’s letter had not violated any laws.



The BOP did not take up the matter.

In Speaker Harrell’s interview (Ref Att 6), he provided the following information: Speaker
Harrell did send a solicitation letter to different SC hospitals seeking business for PSP. He
mentioned, in the letter, his position as Speaker of the SC House of Representatives only to make
sure that the hospitals knew he was contacting them as a private business owner and not in his
official capacity as Speaker of the House. He knew that his name alone was associated with
being the Speaker of the House, so he felt he should make it clear that he was sending the letter
as a private businessman and not as Speaker.

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Page 10

Section 3:
Speaker Harrell’s documentation of campaign fund usage
In the SCPC complaint filed with the OAG, Landess addressed the following issues regarding
Speaker Harrell’s documentation of campaign fund usage: “Robert Harrell has publicly stated
that he failed to maintain certain records to document his expenditures. State law requires
candidates to maintain such records for four years”; “Robert Harrell did not adequately itemize
reimbursements to himself from his campaign account as the law requires.”
SC Code of Laws § 8-13-1302(B) states, “The candidate, committee, or ballot measure
committee must maintain and preserve all receipted bills and accounts required by this article for
four years.”
SC Code of Laws § 8-13-1360(A)(8) states, “… Credit card expenses and candidate
reimbursements must be itemized so that the purpose and recipient of the expenditure are
identified”.

The investigation revealed the following information:


Speaker Harrell provided SLED with a copy of his Campaign Books (Attachment 14)
containing expenditure information from February 2009 through December 2012.



Speaker Harrell provided SLED with a copy of his letters, with documentation,
(Attachment 15) to the SC House Ethics Committee in which he referenced nine
expenditures that he changed. Speaker Harrell reduced the amount of these nine
expenditures and reimbursed the amount of $22,955.41 to his campaign account.



Upon reviewing Speaker Harrell’s Campaign Books, which contained a printout of his
expenditures listed on the SC Ethics Commission’s website, the total number of
expenditures made over the dates listed above was 1,054.



Further review of those records revealed that 285 of the 1,054 expenditures did not
contain receipted bills or invoices from the specific recipient of the expenditure.
However, the 285 expenditures without a receipted bill or invoice did have some type of
explanation provided by Speaker Harrell for the expenditure. The explanations included,

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but are not limited to handwritten notes; typed statements; and personal credit card
statements, which were redacted. See examples (Attachment 16) for details.

Section 4:
Speaker Harrell’s campaign reimbursements for use of his personal aircraft
In the SCPC complaint filed with the OAG, Landess addressed the following issues regarding
Speaker Harrell’s campaign reimbursements for use of his personal aircraft: “Robert Harrell
seems to have broken the law by using campaign funds for personal purposes.”

SC Code of Laws § 8-13-1348(A) deals with the use of campaign funds for personal use and
states, “No candidate, committee, public official, or political party may use campaign funds to
defray personal expenses which are unrelated to the campaign or the office if the candidate is an
officeholder nor may these funds be converted to personal use. The prohibition of this
subsection does not extend to the incidental personal use of campaign materials or equipment nor
to an expenditure used to defray any ordinary expenses incurred in connection with an
individual's duties as a holder of elective office.”

The investigation revealed the following information:
1. Ownership of the Cirrus SR22 aircraft
 Speaker Harrell advised (Ref Att 6) that he did reimburse himself for use of his
personal aircraft, a Cirrus SR22, for campaign and office related travel. He did
not charge a pilot’s fee for operating his aircraft. The Cirrus SR22 is registered
to Pierpont Air, LLC, which is a company owned by Speaker Harrell. The only
asset of Pierpont Air, LLC, is the Cirrus SR22.
 According to the SC Secretary of State website, the business filing for Pierpont
Air, LLC, was reserved by Speaker Harrell in 2004, but the listed registered
agent for Pierpont Air, LLC, is John D. Harrell, Esq., Speaker Harrell’s brother.

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Page 12
 The Federal Aviation Administration (FAA) indicates that the aircraft with FAA
registration Number N749CD is a 2001 Cirrus SR22 and is registered to Pierpont
Air, LLC.

2. Aircraft Expenses
 Speaker Harrell provided documentation (Attachment 17) which indicated how
he determined the cost per flight hour to operate his 2001 Cirrus SR22 aircraft.
This documentation included the following items: fuel, oil, and oil change;
engine and prop reserves; insurance; maintenance; property taxes; data cartridge
updates; interest expense; airplane hangar fee; depreciation expense. Speaker
Harrell did not provide receipts or invoices for the expenses he listed above.
According to Speaker Harrell’s calculations, his cost per hour to operate between
2008 and 2011 was $813.84. Further documentation provided by Speaker
Harrell indicated that a flight from Charleston to Columbia in a leased aircraft
from the company Image Air would cost $706.25 per hour. The Image Air cost
per hour included a pilot’s salary.
 Speaker Harrell decided (Ref Att 6) to charge his campaign $615.00 per hour to
operate his Cirrus SR22 Aircraft, because he wanted to make sure that he was
charging less than what it would actually cost to operate his aircraft, if anyone
asked.
 Speaker Harrell’s documentation (Ref Att 17) indicates the direct operating cost
(fuel, oil, oil change, engine and prop reserves) per hour of his aircraft is
$111.55.
 The fixed operating cost of an aircraft would include: inspections; (some)
maintenance; data updates (avionics); property taxes; insurance; interest expense;
airplane hangar fee; depreciation expense. The fixed operating costs of an
aircraft exist for an owner whether the aircraft is being flown or not, if the
aircraft is intended for use.
 Speaker Harrell includes fixed operating costs in the total operating cost of his
aircraft.

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Page 13
3. Reimbursements
 According to documentation (Attachment 18) provided by Speaker Harrell, he
reimbursed himself six times for airplane expenses for a total of $93,958.50
between 2009 and 2012. He provided detailed flight logs for five of these
expenses. When asked about the sixth flight log, Regina Keene (Assistant to
Speaker Harrell) told Lt. Bolchoz that this flight log was outside the four-year
requirement for recordkeeping and was not available.
 The expenditure on January 12, 2009, of $21,825.00 was listed as an airplane
reimbursement. Due to the fact this expenditure was outside the four year
requirement for recordkeeping, the flight log was not available.
 The expenditure on June 3, 2009, of $22,008.00 involved “35 Legs” (flights)
totaling 35.7 flight hours. Speaker Harrell documented the expenditure with the
following: 35.7 hours at the rate of $615.00 per hour is $21,955.50 with a
miscellaneous amount of $52.50. These “35 Legs” combined for a total of 16
trips. Of these 16 trips, ten trips were to Columbia from Charleston and back for
General Assembly business. Two other trips were for funerals, and one trip was
for “Freshmen orientation” and “Hardwick”. A trip made to Greenville to speak
to the “Greenville First Monday Club”, and a trip made to Miami for the NSC
Executive Committee meeting. On March 18, 2009, Speaker Harrell flew to Fort
Lauderdale, FL, for a baseball tournament involving a local high school. He took
three constituents with him, to include the coach’s wife and siblings of two
players. When asked if he considered the Ft. Lauderdale trip to be an ordinary
expense incurred in connection with the duties of his office, he replied, “Yes.”
When he was asked for an itinerary for this trip and asked what public business
was conducted on this trip, he replied, “Going to Florida was a see and be seen
trip with my constituents. The majority of the time was spent at the stadium and
I do not have an itinerary.” (Attachment 19)
 The expenditure on November 24, 2009, of $12,248.50 involved “19 Legs”
totaling 19.9 flight hours. Speaker Harrell documented the expenditure with the
following: 19.9 hours at the rate of $615.00 per hour is $12,238.5 and a
miscellaneous amount of $10.00. These “19 Legs” combined for a total of nine

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trips. Of these nine trips, three trips were to Columbia from Charleston and back
for General Assembly business. On a trip between September 11, and September
12, 2009, Speaker Harrell documented that he flew from Charleston to Atlanta
and then to Athens and back to Charleston. This trip was for a meeting with the
“Georgia Gov, Speaker and Pres of UGA to talk about Vet School”.
 The expenditure on January 6, 2010, of $8,092.32 involved “12 Legs” totaling
10.2 flight hours and a trip using Jones Air to travel to a “NSC” meeting.
Speaker Harrell documented the expenditure with the following: 10.2 hours at the
rate of $615.00 per hour is $6,273.00; a Jones Air Flight expense of $1,804.32; a
miscellaneous amount of $15.00. These “12 Legs” combined for a total of six
trips. Of these six trips, five trips were to Columbia from Charleston and back
for General Assembly business. One trip was to Greenville to speak at the “First
Monday Club”. The Jones Air Flight was for an expense involving a NSC
meeting.
 The expenditure on July 7, 2010, of $14,279.00 involved “21 Legs” totaling 23.2
flight hours. Speaker Harrell documented the expenditure with the following:
23.2 hours at the rate of $615.00 per hour is $14,268.00 and a miscellaneous
amount of $11.00. These “21 Legs” combined for a total of ten trips. Of these
ten trips, seven trips were to Columbia from Charleston and back for General
Assembly business. The other three trips involved the following: “Clemson
visit”; “Hamilton”; “Ribbon cutting MYR General Aviation Airport”.
 The expenditure on May 27, 2011, of $17,325.00 involved “30 Legs” totaling
26.4 flight hours. Speaker Harrell documented the expenditure with the
following: 26.4 hours at the rate of $655.00 per hour is $17,292.00 and a
miscellaneous amount of $32.00. These “30 Legs” combined for a total of
fourteen trips. Of these fourteen trips, five trips were to Columbia from
Charleston and back for General Assembly business. The other nine trips
involved the following: “Parker”; “Allison”; “Springer”; “Duncan”; “Mulvaney”;
“Lexington GOP”; “Visit ICAR”; “Visit with Business”; “Mtg with CEOs and
Graham”.

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Page 15
Further review of the facts surrounding Speaker Harrell’s airplane reimbursements revealed the
following:


Speaker Harrell paid reimbursements for his aircraft in 2009, 2010, and 2011 based on a
formula which uses 2008 through 2011 information.



Of the five airplane expenditures for which Speaker Harrell provided an explanation, four
expenditures used the amount of $615.00 per hour, and one used $655.00 per hour. He
provided no explanation for the difference in the two amounts used.



All five airplane expenditures resulted in a miscellaneous amount left over. The
calculation should not result in a miscellaneous amount.



Speaker Harrell produced specific figures for his fixed operating cost, but he did not
produce paperwork showing how he produced these figures. The amount of property
taxes paid on the aircraft between 2008 and 2011, was checked. Speaker Harrell
provided the amount of $19,496.72 as the Charleston County property taxes paid on the
Cirrus SR22. The Charleston County tax office receipts (Attachment 20) showed the
amount of $18,798.72 was paid for taxes between 2008 and 2011, with an additional
amount of $1,070.05 as a local option sales tax credit.



According to Speaker Harrell’s response to questions (Ref Att 19), he deducted airplane
expenses from his income taxes. In his ongoing cooperation with this investigation,
Speaker Harrell allowed the OAG and SLED to review his 2009-2012 federal and state
tax returns at the office of his attorney, Gedney M. Howe, III. As of this report, the OAG
is still evaluating this information.

Section 5:
Speaker Harrell’s campaign fund usage
In the SCPC complaint filed with the OAG, Landess addressed the following issues regarding
Speaker Harrell’s campaign fund usage: “Robert Harrell seems to have broken the law by using
campaign funds for personal purposes.”

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Page 16
In reviewing Speaker Harrell’s expenditures between 2009 and 2012, SLED Agents referenced
the State Ethic’s Commission website for documented expenditures during that time frame.
According to the website, between 2009 and 2012, Speaker Harrell’s campaign account listed
1,057 expenditures totaling $1,005,305.65 spent. Of this amount and during the same period,
Speaker Harrell reimbursed himself $294,335.22 for expenses. Of these expenses, $93,958.50
was reimbursed for use of his personal aircraft with a listed explanation of legislative travel as
the reason for the expense. Another $96,381.46 was spent for other legislative travel, and an
amount of $70,286.46 was reimbursed for his Administrative Assistant’s salary in Charleston,
SC, Regina Keene. According the Harrell’s campaign books (Ref Att 14), Keene, who is
employed by Speaker Harrell’s State Farm business, spent 70 percent of her time on campaign or
SC House related business, so Speaker Harrell reimbursed himself 60 percent of Keene’s salary
from his campaign fund. These three categories accounted for $260,626.42 of the monies
Speaker Harrell reimbursed to himself.

After reviewing the campaign books provided by Speaker Harrell concerning these expenditures,
Lt. Bolchoz and Lt. Baker questioned the Speaker about his documentation. Lt. Bolchoz
provided spreadsheets (Attachment 21) that listed expenditures and asked for additional
information. See spreadsheets for details. A large number of the reimbursements questioned by
Lt. Bolchoz and Lt. Baker concerned travel reimbursements for Speaker Harrell, his family, and
his staff. The following are a few of the reimbursements discussed:

A trip to Ft. Lauderdale, FL, between March 18, and March 21, 2009, was listed as part of the
airplane expenditure on June 3, 2009, for $22,008.00. Speaker Harrell logged the flight time on
this trip as 6.3 hours at $615.00 an hour for a total of $3,874.50. He flew constituents to a
baseball tournament in Florida and said the trip was to see and be seen by his constituents.
August 15-19, 2009, Speaker Harrell attended the 63rd annual meeting of the Southern
Legislative Conference (SLC) in Winston-Salem, NC. The trip was paid for out of the campaign
account in at least three different expenditures.

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A March 29, 2010, expenditure of $954.81 paid for the travel of Gregory Foster and Ashley
Foster to an SLC fund raising event in Washington, D.C. Gregory Foster is the communications
director for Speaker Harrell, and Ashley Foster is Gregory’s wife. This expenditure was paid out
of the campaign account.

A July 28, 2010, expenditure of $19,273.63 paid for three different trips, which are as follows:
the 2010 National Speakers Conference (NSC) Annual meeting in Annapolis, MD, June 16-20,
2010; a trip to the Wizarding World of Harry Potter in Orlando, FL, June 17-19, 2010; and the
2010 State Legislative Leaders Foundation (SLLF) International Program in Dublin, Ireland,
August 17-20, 2010. On September 19, 2012, Speaker Harrell changed the amount of this
expenditure to $14,224.96 in his letter to the House Ethics Committee.
 NSC meeting in Annapolis, MD – Speaker Harrell is a member of the NSC and believes
it is an ordinary expense of his office to attend these events. The dates of this trip
coincide with the trip below to Orlando, FL.
 Wizarding World of Harry Potter – Speaker Harrell provided a copy of an invitation
(Attachment 22) to the opening of the Wizarding World of Harry Potter at Universal
Studios in Orlando, FL, as his itinerary for this trip. The invitation was for June 17,
2010, from 8:00 PM to 11:00 PM and did not indicate for whom the invitation was
addressed. Speaker Harrell also advised that he went on the trip to meet “with film
company executives in regard to film legislation that was under consideration.” His
wife traveled with him. He did not provide any documentation indicating who the film
company executives were or where and when the meeting took place.
 SLLF International Program in Dublin, Ireland – Speaker Harrell was the President of the
NSC when he attended this event. His wife traveled with him. He provided the
following explanation: “This was paid from the campaign account in lieu of these
expenses being paid with state funds.”

Speaker Harrell also listed trips for conferences or committee meetings to the following
locations: Sea Island, GA (NSC October 21-25, 2009); Key Biscayne, FL (NSC January, 15-172010); Washington, DC (NSC January 13-15, 2011); Kiawah Island, SC (NSC February 4-6,

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2011); Charleston, SC (NSC September 7-11, 2011); University of Massachusetts (SLLF
September 30 through October 3, 2010); San Francisco, CA (NSC January 27-29, 2012);
Anchorage, Alaska (NSC August 19-23, 2012).

In documentation (Ref Att 19) provided by Speaker Harrell, he referenced § 8-13-1348(A) and
(B):
(A) No candidate, committee, public official, or political party may use
campaign funds to defray personal expenses which are unrelated to the
campaign or the office if the candidate is an officeholder nor may these
funds be converted to personal use. The prohibition of this subsection
does not extend to the incidental personal use of campaign materials or
equipment nor to an expenditure used to defray any ordinary expenses
incurred in connection with an individual's duties as a holder of elective
office.
(B) The payment of reasonable and necessary travel expenses or for food
or beverages consumed by the candidate or members of his immediate
family while at, and in connection with, a political event are permitted.

Speaker Harrell provided this as an explanation for his reimbursement of travel with or without
his family and for Greg Foster’s travel as a member of his staff.

In an interview (Attachment 23), Greg Foster advised that Speaker Harrell was allowed by state
law to use campaign funds to pay for travel by his staff as an ordinary expense of his office.
This allowed the Speaker to use campaign funds instead of state funds for his staff’s travel
expenses. Some of the trips he made with the Speaker were to meetings concerning the Southern
Legislative Conference (SLC). Their goal in attending these meetings was to get Speaker Harrell
elected to the position of chairman or president. As chairman or president, Speaker Harrell could
hold the conference in South Carolina, which would produce an economic benefit for the state.
Foster gave the example of the SLC that was held in Charleston, SC, which hosted some 3000
people. According to Foster, a College of Charleston Economic Impact statement suggested the
conference generated tens of millions of dollars for the state.

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Page 19
In Speaker Harrell’s letters (Ref Att 15) to the House Ethics Committee, he provided the
committee with revised amounts for nine expenditures. He reimbursed his campaign account
$22,955.41 because he did not have documentation for, all of, or some part of, the nine
expenditures. In his campaign books (Ref Att 14) concerning the nine expenditures, the Speaker
used copies of American Express (AmEx) Credit Card statements as justification for the
expenses. These AmEx statements were limited in information by redaction and the number of
pages provided. SLED Agents requested the original un-redacted versions of the AmEx credit
card statements for two AmEx accounts and one BB&T credit card account. Agents were
initially provided with a portion of the statements for AmEx account ending in

. Agents

reviewed the statements and found discrepancies in four of the nine expenditures. They are as
follows: the December 1, 2009, expenditure for $2,980.74; the July 28, 2010, expenditure for
$19,273.63; the October 15, 2010, expenditure for $2,591.56; and the January 7, 2011,
expenditure for $4,241.46.

The details concerning these expenditures are:
1. December 1, 2009, expenditure for $2,980.74
 Speaker Harrell, in his second interview (Attachment 24), advised he signified
campaign expenses on his personal credit card statements by making a mark by
the charge.
 On December 1, 2009, Speaker Harrell signed a check made out to him for
$2,980.74.
 In 2012, Speaker Harrell did a self-review of his campaign expenses and revised
the amount of this expenditure to $2,148.25.
 On September 19, 2012, Speaker Harrell sent a signed letter to the House Ethics
Committee in part stating, “This action is being taken because of the
misplacement of the necessary supporting documentation and receipts related to
specific campaign expenditures from my campaign account. While I am
confident that these expenses are legitimate campaign expenditures, I am
cognizant of Section 8-13-1302(B) of the South Carolina Code that requires a
candidate ‘maintain and preserve all receipted bills and accounts required by this
article for four years’.”

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Page 20
 On September 17, 2013, SLED Agents obtained the original AmEx credit card
statements from Speaker Harrell.
 The un-redacted AmEx statement with the closing date of November 5, 2009, had
marks made by charges which Speaker Harrell had advised he used to denote
campaign expenses.
 The sum of these charges with marks made by them is $2,980.74.
 The $2,980.74 was paid to Speaker Harrell with campaign check # 1880.
 When the un-redacted statement was compared to the campaign book statement,
the comparison indicated that the following items were removed from the
original expenditure: Cindy’s Backstreet Kitchen, St. Helena, CA ($100.14);
Scala-Bar Drake, San Francisco, CA ($173.54); Bodega Bay ($151.92); National
Car rental, San Francisco, CA ($227.67); Parc 55 Hotel, San Francisco, CA
($317.40). These amounts total $970.67.
 The original AmEx statement with the closing date of November 15, 2009, would
indicate that Speaker Harrell does possess documentation on how the $2,980.74
was spent, despite his letter to the House Ethics Committee.
 When asked about these documented purchases, Speaker Harrell advised that the
original AmEx statements were working copies, but the information he provided
in 2012 is the actual campaign cost. Therefore, he corrected the amount of this
expenditure to $2,148.25.
 A spreadsheet produced by Lt. Baker, along with supporting documentation,
(Attachment 25) would indicate that items were removed from the original
expenditure and different items were added to change the amount of the
expenditure.
 When asked if any of the money spent on the original nine expenditures was for
personal use, Speaker Harrell said no.

2. July 28, 2010, expenditure for $19,273.63
 Speaker Harrell, in his interview (Ref Att 24), advised he signified campaign
expenses on his personal credit card statements by making a mark by the charge.

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 On July 28, 2010, Speaker Harrell signed a check made out to him for
$19,273.63.
 In 2012, Speaker Harrell did a self-review of his campaign expenses and revised
the amount of this expenditure to $14,224.96.
 On September 19, 2012, Speaker Harrell sent a signed letter to the House Ethics
Committee in part stating, “This action is being taken because of the
misplacement of the necessary supporting documentation and receipts related to
specific campaign expenditures from my campaign account. While I am
confident that these expenses are legitimate campaign expenditures, I am
cognizant of Section 8-13-1302(B) of the South Carolina Code that requires a
candidate ‘maintain and preserve all receipted bills and accounts required by this
article for four years’.”
 In 2013, SLED Agents obtained the original AmEx credit card statements from
Speaker Harrell.
 The original/un-redacted AmEx statement with the closing date of July 16, 2010,
has the amount of $19,273.63 handwritten at the top of the statement. Speaker
Harrell advised he wrote this amount at the top of the statement in 2012, when he
was doing his review of the campaign account.
 The original statement also shows marks made by charges which Speaker Harrell
has advised he used to denote campaign expenses.
 The sum of the charges with marks made by them is $20,924.83.
 The $20,924.83 was paid to Speaker Harrell with campaign check # 2049 for
$19,273.63 and check # 2051 for $1,651.20.
 Check # 2051, according to Speaker Harrell’s Campaign Book for 3rd Quarter
2010, paid for two purchases, at the Apple Webstore Austin, of $1,567.35 and
$83.85, respectively. These purchases were marked on the original AmEx
statement with the closing date of July 16, 2010.
 The remaining items marked on the original statement total $19,273.63.
 When the un-redacted statement was compared to the campaign book statement,
the comparison indicated that the following items were removed from the
original expenditure: three purchases at the Wizarding World of Harry Potter in

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Orlando, FL ($339.75); one purchase at Gemco Aviation Service, North Lima,
OH ($827.28); six purchases for a trip to Martha’s Vineyard for Speaker Harrell,
Catherine Harrell, and Charlotte Harrell ($3,880.14); and a PayPal purchase
($3,759.50). These amounts total $8,806.67.
 The original AmEx statement with the closing date of July 16, 2010, would
indicate that Speaker Harrell does possess documentation on how the $19,273.63
was spent, despite his letter to the House Ethics Committee.
 When asked about these documented purchases, Speaker Harrell advised that the
original AmEx statements were working copies, but the information he provided
in 2012 is the actual campaign cost. Therefore, he corrected the amount of this
expenditure to $14,224.67.
 A spreadsheet produced by Lt. Baker, along with supporting documentation,
(Attachment 26) would indicate that items were removed from the original
expenditure and different items were added to change the amount of the
expenditure.
 When asked if any of the money spent on the original nine expenditures was for
personal use, Speaker Harrell said no.

3. The October 15, 2010, expenditure for $2,591.56
 This expenditure actually occurred on September 15, 2010, and not October 15,
2010, as documented by Speaker Harrell’s Campaign Books.
 Speaker Harrell, in his interview (Ref Att 24), advised he signified campaign
expenses on his personal credit card statements by making a mark by the charge.
 On September 15, 2010, Speaker Harrell signed a check made out to him for
$2,591.56.
 In 2012, Speaker Harrell did a self-review of his campaign expenses and revised
the amount of this expenditure to $1,474.74.
 On September 19, 2012, Speaker Harrell sent a signed letter to the House Ethics
Committee in part stating, “This action is being taken because of the
misplacement of the necessary supporting documentation and receipts related to
specific campaign expenditures from my campaign account. While I am

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confident that these expenses are legitimate campaign expenditures, I am
cognizant of Section 8-13-1302(B) of the South Carolina Code that requires a
candidate ‘maintain and preserve all receipted bills and accounts required by this
article for four years’.”
 On September 17, 2013, SLED Agents obtained the original AmEx credit card
statements from Speaker Harrell.
 The un-redacted AmEx statement with the closing date of August 17, 2010, had
marks made by charges which Speaker Harrell had advised he used to denote
campaign expenses.
 The sum of the charges with marks made by them is $2,591.56.
 The $2,591.56 was paid to Speaker Harrell with campaign check # 2074.
 When the un-redacted statement was compared to the Campaign Book statement,
the comparison indicated that the following items were removed from the
original expenditure: a Verizon bill ($692.45); a purchase at Office Depot
($80.57); and a US Airways ticket to Boston for Stephen Graves ($405.80).
These amounts total $1,178.82.
 The original AmEx statement with the closing date of August 17, 2010, would
indicate that Speaker Harrell does possess documentation on how the $2,591.56
was spent, despite his letter to the House Ethics Committee.
 When asked about these documented purchases, Speaker Harrell advised that the
original AmEx statements were working copies, but the information he provided
in 2012, is the actual campaign cost. Therefore, he corrected the amount of this
expenditure to $1,474.74.
 A spreadsheet produced by Lt. Baker, along with supporting documentation,
(Attachment 27) would indicate that items were removed from the original
expenditure and different items were added to change the amount of the
expenditure.
 When asked if any of the money spent on the original nine expenditures was for
personal use, Speaker Harrell said no.

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Page 24
4. The January 7, 2011, expenditure for $4,241.46
 Speaker Harrell, in his interview (Ref Att 24), advised he signified campaign
expenses on his personal credit card statements by making a mark by the charge.
 On January 7, 2011, Speaker Harrell signed a check made out to him for
$4,609.89. According to the Campaign Books for 1st Quarter 2011, this check
combined the expenditures numbered 47 and 48, for $4,241.46 and $368.43
respectively.
 In 2012, Speaker Harrell did a self-review of his campaign expenses and revised
the amount of the $4,241.46 expenditure to $3,659.49. However, when the items
on the changed expenditure are totaled, the sum is $3,660.06.
 On September 19, 2012, Speaker Harrell sent a signed letter to the House Ethics
Committee in part stating, “This action is being taken because of the
misplacement of the necessary supporting documentation and receipts related to
specific campaign expenditures from my campaign account. While I am
confident that these expenses are legitimate campaign expenditures, I am
cognizant of Section 8-13-1302(B) of the South Carolina Code that requires a
candidate ‘maintain and preserve all receipted bills and accounts required by this
article for four years’.”
 On September 17, 2013, SLED Agents obtained the original AmEx credit card
statements from Speaker Harrell.
 The un-redacted AmEx statement with the closing date of December 17, 2010,
had marks made by charges which Speaker Harrell had advised he used to denote
campaign expenses.
 The sum of the charges with marks made by them is $4,241.46.
 When the un-redacted statement was compared to the Campaign Book statement,
the comparison indicated that the following items were removed from the
original expenditure: three separate purchases from the Athletic Ticket Office,
Cola, SC (totaling $990.00) and a charge at the Hilton Full service, Cola, SC
($541.47). These amounts total $1,531.47.
 Of interest, the expenses added by Speaker Harrell to the changed expenditure
amount in the campaign books are from a later AmEx statement with the closing

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date of January 17, 2011. Speaker Harrell signed the check made out to him for
the expense amount on January 7, 2011. This was ten days before the
information he used was available in statement form.
 The original AmEx statement with the closing date of December 17, 2010, would
indicate that Speaker Harrell does possess documentation on how the $4,241.46
was spent, despite his letter to the House Ethics Committee.
 When asked about these documented purchases, Speaker Harrell advised that the
original AmEx statements were working copies, but the information he provided
in 2012, is the actual campaign cost. Therefore, he corrected the amount of this
expenditure to $3,659.49.
 A spreadsheet produced by Lt. Baker, along with supporting documentation,
(Attachment 28) would indicate that items were removed from the original
expenditure and different items were added to change the amount of the
expenditure.
 When asked if any of the money spent on the original nine expenditures was for
personal use, Speaker Harrell said no.

Of the nine expenditures changed by Speaker Harrell, three expenditures were changed to an
amount of zero, and the full amount of these expenditures was contributed back to the campaign
account by Speaker Harrell. Those three expenditures totaled $13,008.67. As of this report,
SLED Agents have not been able to determine how these funds were spent.
Lt. Baker obtained documents (Attachment 29) from the SC Comptroller General’s Office that
listed expenses paid to Speaker Harrell by the State of SC between November 2009, and March
2013. The documents provided amounts paid for the following listings: In-State Automobile
Mileage; In-State Subsistence Allowance; Out-of State Lodging; Per Diem; In-State Lodging;
and In-State Miscellaneous Travel Expenses.

Under the Out-of-State Lodging entry, with a posting date of December 14, 2009, the SC
Comptroller General’s Office listed an amount of $1,839.91 paid to Speaker Harrell. Additional
documents (Attachment 30) provided by the SC Comptroller General’s Office indicated the

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payment was a reimbursement for a trip to the National Speaker’s Conference in Georgia, on
October 21-24, 2009. Speaker Harrell’s personal BB&T credit card statements were used to
show the charged amounts and credits. The October 16, 2009, BB&T statement indicated that
the $1,839.91 paid to Speaker Harrell by the State of SC was a portion of the statement’s total
amount due of $4,149.09.
The $ 4,149.09 amount lead Lt. Baker to review Speaker Harrell’s Campaign Books for the 4th
Quarter of 2009 (Attachment 31). Lt. Baker located a payment of $4,149.09 to Speaker Harrell
from his campaign account, on November 1, 2009. Speaker Harrell provided the same October
16, 2009, BB&T credit card statement and NSC trip as justification for this campaign
expenditure. The payment from Speaker Harrell’s campaign account and the payment from the
State of SC indicate that Speaker Harrell was reimbursed twice for the same expenses.

In the request to Speaker Harrell (Ref Att 21) for additional documentation, Lt. Bolchoz asked
about an expenditure of $5,390.92, on January 4, 2011. According to Speaker Harrell’s
Campaign Books for 1st Quarter 2011, the $5,390.92 amount covered expenditures 50, 51, 52,
and 53 (Attachment 32), which were marked on Speaker Harrell’s BB&T credit card statement
ending December 16, 2010. There were no receipts or invoices from these merchants. One of
the charges marked on the BB&T statement was at a Goodyear Auto Service Center, in
Columbia, SC, for $865.81. Lt. Bolchoz referenced the Goodyear charge when he listed this
expenditure. Speaker Harrell provided the following as an explanation: “I don’t remember why
the Goodyear charge. I do keep an old Buick at the Columbia airport so when I fly in it is
available. May have been repairs on that car which is only used for this purpose and does not
receive reimbursement on milage or anything else.”

On April 16, 2013, Lt. Baker spoke with Charles Reid, the Clerk of the SC House of
Representatives, by telephone. Reid provided the following information: as Clerk of the House,
he, along with his staff, manages the disbursement of state funds to House members. They keep
track of mileage, subsistence allowance, and other expenses. According to Reid, the SC Code of
Laws § 2-3-20 (Attachment 33) requires the state to pay members of the General Assembly
mileage for one round trip per week, while the General Assembly is in session. The member

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must be present to receive the mileage reimbursement. If the General Assembly is not in session,
the member must fill out a state travel voucher to receive mileage.

In 2008, the House froze the mileage rate at 44.5 cents per mile. House members are paid the
44.5 cents per mile rate whether they drive a hybrid type vehicle, a gas guzzler, or fly an
airplane. Reid, or his staff, decides the most direct route from the House members’ homes to the
General Assembly. In the case of Speaker Harrell, one round trip (Ref Att 29) would be 200
miles, which equates to $89.00 at 44.5 cents per mile. The State of SC makes these payments in
two week intervals, which would equate to a $178.00 mileage reimbursement for Speaker Harrell
every two weeks.

According to Reid, House members also receive a subsistence allowance of $131.00 per day of
attendance during session of the General Assembly. The subsistence allowance is for food and
lodging expenses that occur while the General Assembly is in session. The subsistence
allowance is provided to the members of the General Assembly in a “proviso” to the
Appropriations Act.
According to the documents (Ref Att 29) from the SC Comptroller General’s Office, Speaker
Harrell did receive mileage reimbursements from the State of SC between November 2, 2009,
and March 7, 2013, totaling $6,853.00. During that same period, he received $27,772.00 in
subsistence allowance from the state. According to Speaker Harrell’s campaign books (Ref Att
14), the campaign account has also reimbursed Speaker Harrell for food, travel, and lodging
while he was in Columbia, SC, for General Assembly business.
In addition to Speaker Harrell’s reimbursements to himself, he has also provided campaign funds
to the following sources of interest:
1. Gregory Foster – Communications Director for Speaker Harrell $55,982.94
 $40,000.00 was paid for services to Speaker Harrell’s website. The attached
document (Attachment 34) was provided in Speaker Harrell’s campaign books
as an invoice documenting the work done by Foster. The following sources were
also paid for services to the Speaker’s website: Root Loud ($3,640.00); Trisha

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Page 28
Ostrowski ($4,000.00); Donahue Direct ($9,609.16). Some of these sources
were paid for work on the Speaker’s website, along with Foster being paid for
work.
 In an interview (Ref Att 23), Foster advised he worked on the Speaker’s website
on his on time with his own equipment.
 $15,982.94 was paid to Foster for travel, food, office expenses, phones, and other
computer services. See Attachment 35 for examples of these expenses.
 In an interview (Ref Att 23), Foster advised that Speaker Harrell was allowed by
state law to use campaign funds to pay for travel by his staff as an ordinary
expense of his office. This allowed the Speaker to use campaign funds instead of
state funds for his staff’s travel expenses.

2. Trisha Ostrowski $4,436.80
 Speaker’s website (Attachment 36) – $4,000.00
 Computer services – $436.80

3. Root Loud $4,500.00
 Speaker’s website (Attachment 37) – $3,640.00
 Computer services / Legislative ad – $860.00

4. Donahue Direct $11,759.18
 Speaker’s website (Attachment 38) – $9,609.18
 Legislative ads and emails – $2,150.00

5. Sponsorships $47,940.00
 Harrell provided campaign funds to different entities as sponsorships. The
following are some examples of these sponsorships: Schools; Clubs; Republican
Party affiliated groups; United Way; Churches; Baseball, Softball and Basketball
Teams. See Speaker Harrell’s campaign books (Ref Att 14) for details.
 A $3,500.00 Sponsorship for an Inaugural Gala (Attachment 39) was paid to
Alan Wilson for Attorney General from Speaker Harrell’s campaign account.

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 Reference § 8-13-1340 for any potential conflict.
6. American Express $22,580.33 – Personal credit cards used for campaign purposes
 Credit Card processing fee and banking charges (Attachment 40) – $670.08
 Computer services, Legislative travel, Office expenses, Legislative dinners,
Phones, Honorarium – House Members – $21,910.25
 American Express Platinum Card account ending

– Receives

Membership Rewards Points
 American Express Platinum Delta SkyMiles Card account ending

–

receives Delta SkyMiles
7. Jeannie Potter – Administrative Assistant to Speaker Harrell $7,659.97
 $5,900.00 in Petty Cash/Office Expenses (Attachment 41). Dates and amounts:
March 29, 2009 - $1,400.00; January 6, 2010 - $1,000.00; October 25, 2010 $1,000.00; November 29, 2010 - $1,000.00; April 15, 2011 - $1,000.00;
February 16, 2012 - $500.00
 § 8-13-1348(E) A candidate or a duly authorized officer of a committee may not
withdraw more than one hundred dollars from the campaign account to establish
or replenish a petty cash fund for the candidate or committee at any time, and at
no time may the fund exceed one hundred dollars. Expenditures from the petty
cash fund may be made only for office supplies, food, transportation expenses,
and other necessities and may not exceed twenty-five dollars for each
expenditure.
8. Mitch Dorman – Sergeant at Arms of the SC House of Representatives
 Flags (Attachment 42) – $4,733.00

9. E System Solutions $22,779.52
 E System Solutions works on Speaker Harrell’s wireless access at his Charleston
office, at his home office, and for his staff in Columbia to be able to access his
calendar and contacts.

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 Invoice 3099 for February 28, 2009 (Attachment 43) – Service request 1731 –
Set up Bobby’s wife’s new computer at their home.
 Invoice 3174 for March 31, 2009 (Attachment 44) – Service Request Notes:
check all five computers at the house
 Invoice 3213 for April 30, 2009 (Attachment 45) – Service Request 2372 –
Wireless at Bobby’s home not working. Did work on Cathy’s and family PCs.
 Invoice 3568 for December 30, 2009 (Attachment 46) – Service Request 4152 –
Wireless not working at house. “Rebooted switch downstairs and router upstairs.
I think the network cable was unplugged from the wall the whole time.
Everything is working fine now. Also reconnected Charlotte’s Wii to the
network.”
 Invoice 3809 for June 30, 2010 (Attachment 47) – Service Request 4999 – Work
on Trey’s computer. Hard drive dead. HP shipping a new hard drive and
recovery disks. Recovered all the data from Trey’s hard drive and put it on my
external hdd. Finished reloading Trey’s computer and transferred data. Service
Request 5005 – Return computer to Cathy; Set up printers on her PC.
 Invoice 4025 for December 31, 2010 (Attachment 48) – Service Request 6001 –
Trey’s Internet not working. Reset Apple wireless router to factory setting and
set it up again. After that everything worked.

10. O. L. Thompson Construction $10,469.88 (Attachment 49)
 Legislative Travel – $6,647.50
 Trip to Myrtle Beach, SC – $2,092.38
 Trip to Darlington, SC – $1,730.00

11. Clemson University $2,091.00 (Attachment 50)
 Constituent Appreciation – $1,313.00
 Campaign Chairman Appreciation – $778.00

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12. India Hazzard Pickelsimer $963.31 (Attachment 51)
 The above amount was reimbursed to Hazzard Pickelsimer for campaign expenses
related to work on Speaker Harrell’s campaign for SC House District 114.
 This campaign work was carried out by Hazzard Pickelsimer while she was the
Executive Director of the Palmetto Leadership Council.

13. Palmetto Leadership Council $605.00 (Attachment 52)
 Reimbursement for travel
 Speaker Harrell (Ref Att 6) does not remember this trip.

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This case file will be forwarded to the proper prosecutorial authority for review.

______________________________
Lt. Kevin W. Baker

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Attachments
1.

Letter of Request from the OAG

2.

Letter of Complaint from E. Ashley Landess (SCPC)

3.

MOIs – E. Ashley Landess

4.

Memorandum from Jane Shuler in reference to the JMSC

5.

Letter to the SC Secretary of State from Shuler reference the JMSC

6.

MOI Robert W. Harrell, Jr. – August 13, 2013

7.

Letter from JMSC Chairman Greg Delleney, Jr.

8.

MOI – Donald Hottel

9.

MOI – Lee Ann Bundrick

10.

MOI – Clelia Sanders

11.

MOI – Robert “Bobby” Bradham

12.

MOI – Randall Bryant

13.

MOI – Sheila Young

14.

Harrell’s Campaign Books 2009-2012

15.

Harrell’s Letters to the SC House Ethics’ Committee

16.

Examples of paperwork used as receipts and invoices in Harrell’s Campaign Books

17.

Harrell’s calculations on Cirrus SR-22’s costs per hour to operate

18.

Documents provided by Speaker Harrell to explain flight costs

19.

Speaker Harrell’s response to questions provided in first interview

20.

Charleston County Tax Receipts on Pierpont Air, LLC, Cirrus SR-22 aircraft

21.

Spreadsheets prepared by Lt. Bolchoz requesting additional documentation on expenses

22.

Invitation to Wizarding World of Harry Potter

23.

MOI – Gregory Foster

24.

MOI – Robert W. Harrell, Jr. – September 30, 2013

25.

Spreadsheet with documents of December 1, 2009, Expenditure for $2,980.74

26.

Spreadsheet with documents of July 28, 2010, Expenditure for $19,273.63

27.

Spreadsheet with documents of October 15, 2010, Expenditure for $2,591.56

28.

Spreadsheet with documents of January 7, 2011, Expenditure for $4,241.46

29.

Documents from the SC Comptroller General’s Office – Payments to Speaker Harrell

30.

Documents from the SC Compt. General’s Ofc. – Reimbursement to Speaker Harrell

31.

A section of Speaker Harrell’s Campaign Books – 4th Quarter of 2009

32.

A section of Speaker Harrell’s Campaign Books – 1st Quarter of 2011

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33.

SC Code of Laws Section 2-3-20

34.

Paperwork documenting Gregory Foster’s work on Speaker Harrell’s website

35.

Examples of Foster’s expenses paid by Speaker Harrell’s Campaign account

36.

Payments to Trisha Ostrowski – Speaker’s website

37.

Payments to Root Loud – Speaker’s website

38.

Payments to Donahue Direct – Speaker’s website

39. $3,500.00 “sponsorship” to Attorney General Alan Wilson for Inaugural Gala
40.

Credit Card processing fees and banking charges

41.

Petty Cash Fund – Jeannie Potter

42.

Flags – Mitch Dorman

43.

E System Solutions Invoice 3099

44.

E System Solutions Invoice 3174

45.

E System Solutions Invoice 3213

46.

E System Solutions Invoice 3568

47.

E System Solutions Invoice 3809

48.

E System Solutions Invoice 4025

49.

Payments to O. L. Thompson Construction

50.

Clemson University – Constituent appreciation

51.

Payments to India Hazzard-Pickelsimer from Speaker Harrell’s campaign account

52.

$605.00 payment to PLC from Speaker Harrell

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