Florida Commission on Ethics
P. O. Drawer 15709, Tallahassee, Florida 32317-5709
"A Public Of ce is a Public Trust"

COMPLAINT
1. PERSON BRINGING COMPLAINT:
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Name: _____________________________________
Telephone Number: ____________________
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Address: ______________________________________________________________________
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City: ______________
County: _________________
State: ____________
Zip Code: __________

2. PERSON AGAINST WHOM COMPLAINT IS BROUGHT:
Use a separate complaint form for each person you wish to complain against:
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Name: __________________________________
Telephone Number: ____________________
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Address: ______________________________________________________________________
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City: ___________________________
County: _____________________
Zip Code: ___________
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Title of of ce or position held or sought: ______________________________________________

3. STATEMENT OF FACTS:
Please provide a full explanation of your complaint, describing the facts and the actions of the
person named above and why you believe he or she violated the law. Include relevant dates and
the names and addresses of persons whom you believe may be witnesses. Please do not submit
more than 15 pages, including this form. Please do not submit video or audio tapes, CDs, DVDs,
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ash drives or other electronic media; such material will not be considered part of the complaint
and will be returned.

4. OATH
I, the person bringing this complaint, do
swear or af rm that the facts set forth in
the foregoing complaint and attachments
thereto are true and correct to the best of
my knowledge and belief.

STATE OF __________________________________
COUNTY OF ________________________________
Sworn to (or af rmed) and subscribed before me this
____________ day of _________________________,
20 _______, by ______________________________.
(name of person making statement)

___________________________________________

______________________________
SIGNATURE OF COMPLAINANT

(Signature of Notary Public)

___________________________________________
(Print, Type, or Stamp Commissioned Name of Notary Public)

CE FORM 50--Effective January 9, 2017
Incorporated by reference in Rule 34-7.010(1)(b), F.A.C.

Personally Known ____ OR Produced Identi cation ___
Type of Identi cation Produced: ____________________

3. STATEMENT OF FACTS
This complaint alleges that Tallahassee Mayor Andrew Gillum may have violated the
Florida Code of Ethics by accepting gifts from a city lobbyist, a city vendor, or someone seeking
to do business with the city in the form of (1) a trip to New York, (2) a ticket to a professional
baseball game, (3) a ticket to a Broadway show, (4) a boat tour of the Statue of Liberty, and (5)
having some or all of these same gifts provided to his brother.
A. Parties
Andrew Gillum is the mayor of the city of Tallahassee. He has been involved in elected
politics his entire adult life and is subject to Florida's Code of Ethics. He was elected to the
Tallahassee City Commission in 2003 at the age of twenty-three. He held that position until he
was elected mayor in 2014.
At all times relevant to this complaint, Adam Corey was a lobbyist registered to lobby the
city of Tallahassee. His lobbying firm is Unconventional Strategies, LLC. He is also a co-owner
of The Edison restaurant and catering company, which is a vendor to the city of Tallahassee. In
addition, The Edison is housed in a building owned by the city and located within the city's
Cascades Park. The Edison was developed with millions of dollars of subsidies from the city.
The Edison has a lease agreement with the city that allows the city to regulate it in many
respects.
At all times relevant to this complaint, Mike Miller identified himself as a real estate
developer interested in developing property within Tallahassee. He claimed to be the president of
Southern Pines Development in Atlanta, Georgia. Miller used Corey and his lobbying firm to set
up meetings with city officials, including Gillum, to discuss Miller's desire to develop an eightacre parcel within the city. Miller also discussed the possibility of extending the boundaries of

the city's community redevelopment area so that his project could receive favorable tax
treatment and other government subsidies.
Media outlets have reported that Miller was an undercover FBI agent during this time,
investigating public corruption in Tallahassee. [Exhibit A] Whether this is true is irrelevant to
this complaint. At all relevant times, Gillum believed Miller was a real estate developer who
wanted to do business with the city.
Marcus Gillum is Mayor Andrew Gillum's brother. He lives in Chicago, Illinois.
B. Background
In August 2016, Gillum traveled to New York, New York, with Corey, Miller, and his
brother. [Exhibit B] At least one picture of Gillum, Corey, and Miller on the trip exists. [Exhibit
C]
While in New York, Gillum and the others attended a New York Mets baseball game,
attended the Broadway show Hamilton, and took a boat tour to see the Statue of Liberty. Further,
media reports have stated that Miller booked a block of rooms at the New York Millennium
Hilton during this time. [Exhibit B] It is also safe to assume the group used an airplane to travel
to New York from Tallahassee, although whether they flew private or commercial is unclear.
Gillum has refused to answer questions about the trip. Still, it is apparent that he broke
some ethics laws on the trip. A thorough commission is necessary to determine precisely which
laws he broke. A full investigation could answer the following:
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Who paid for Gillum's hotel room during the trip?
Who paid for Gillum's meals and drinks on the trip?
Who paid for Gillum's ticket to the Mets game?
Who paid for Gillum's tickets to Hamilton?
How were the tickets to Hamilton obtained given the show was sold out?
Who paid for Gillum's boat tour of the Statue of Liberty?
Who paid for Gillum's air travel to New York?
Did Gillum receive any other gifts on the trip?
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Why has Gillum not reported any of the gifts he received on the trip?

C. Ethics Code Violations
Gillum's actions may have violated some or all of the following laws. First, as mayor,
section 112.3148(4) prohibits Gillum from accepting a gift worth more than $100 from a lobbyist
or a vendor doing business with the city. Gillum knew, or should have known, that the value of
many of, if not all, the gifts he received on the trip exceeded the $100 limit. If the gifts came
from Corey, they were illegal because he was a city lobbyist and city vendor. Moreover, Miller
was seeking to do business with the city.
Further, section 112.3148(3) prohibits Gillum from soliciting any gift from a lobbyist
who has lobbied him or the city within the past twelve months or from a vendor doing business
with the city. At the time of the trip, Corey was both a lobbyist who had lobbied the city within
the past twelve months and a city vendor. Additionally, Miller hoped to do business with the
city.
Gillum's actions also may have violated section 112.313(2), which prohibits him from
soliciting or accepting anything of value that is based on an understanding that his official action
or judgment could be influenced by such a gift. Miller was a real estate developer who wanted to
expand the boundaries of the city's community redevelopment area and wanted other favorable
treatment from city legislation. This was his primary objective in his dealings with Gillum;
therefore, the entire basis of the New York trip was to influence Gillum in his capacity as mayor.
Finally, section 112.313(6) prohibits Gillum from corruptly using his position to obtain a
special benefit for himself or others. In contravention of this statute, Gillum used his position as
mayor to reward himself and his brother with a trip to New York. According to the statute,
"Corruptly means done with a wrongful intent and for the purpose of obtaining . . . any benefit

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resulting from some act or omission of a public servant which is inconsistent with the proper
performance of his or her public duties." ? 112.312(9), Fla. Stat. By accepting a lavish trip to
New York for himself and his brother from a lobbyist and developer seeking favorable treatment
from the city, Gillum acted inconsistently with his duties as a public servant.
D. Conclusion
For all the reasons stated above, there is ample reason for the commission to find this
complaint legally sufficient and to begin investigating Tallahassee Mayor Andrew Gillum.

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