To: Rick Thompson Executive Secretary
From: Tom Plank Commission Attorney
Date: May 26, 2009
Re: In the Matter of Ralph Coleman Richardson, Case No. 2009-0006: Recommendation for Administrative Dismissal

Pursuant to Rule 189-2-.03(5), it is recommended that this matter be administratively dismissed because no evidence has been discovered to provide a basis with which to proceed with this matter under the Ethics in Government Act (Act). The allegations and findings are summarized herein. Respondent is a Councilman for District 2 of the Town of Braselton and is a candidate for Mayor of Braselton. Complainant Joe Greer alleges that Respondent did not properly disclose in-kind campaign contributions in the form of the reservation of a domain name and the construction of a campaign website, in violation of O.C.G.A. § 21-5-34. In addition to the Response, staff has reviewed submitted statements from the president of a campaign consulting service retained by Respondent and its subcontractor, who actually reserved the domain name and constructed the website at issue. No evidence has been discovered to show that the subcontractor’s work for the consulting service was not in the normal course of business or that it was an in-kind contribution to Respondent’s campaign, and absent any such evidence it does not appear that Respondent was required to disclose the subcontractor’s work as an in-kind contribution. See Rule 189-3-.04(2)(a). In addition, no evidence has been discovered to show that Respondent did not properly disclose expenditures to the consulting service at issue. Based upon the foregoing analysis, it is recommended that this case be administratively dismissed pursuant to Rule 189-2-.03(5). Please be advised that nothing will prevent a new investigation on this matter should new or pertinent facts arise, or should the Commission feel such action is necessary to perform its duties or enforce its powers in accordance with the Act.


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