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  • Impeachment Investigation Subpoenas

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    Mike Cason
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    Some of the subpoenas issued today in as part of the investigation into impeachment articles against Gov. Robert Bentley.

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    Some of the subpoenas issued today in as part of the investigation into impeachment articles against Gov. Robert Bentley.

    Droits d'auteur :

    © All Rights Reserved
    Téléchargez comme PDF ou lisez en ligne sur Scribd
    Signaler comme contenu inapproprié
    6K vues51 pages

    Impeachment Investigation Subpoenas

    Transféré par

    Mike Cason
    Some of the subpoenas issued today in as part of the investigation into impeachment articles against Gov. Robert Bentley.

    Droits d'auteur :

    © All Rights Reserved
    Téléchargez comme PDF ou lisez en ligne sur Scribd
    Signaler comme contenu inapproprié
    sur 51
    BEFORE THE JUDICIARY COMMITTEE OF THE ALABAMA HOUSE OF REPRESENTATIVES, TO: The Honorable Robert Bentley Governor of Akama SUBPOENA clo Joseph C. Espy III, Esq. MrLtox, Esty & WILLIAM P.C. 255 Dexter Avenue Montgomery, Alabama 36104 PURSUANT TO THE COMMITTEE RULES OF THE HOUSE JUDICIARY COMMITTEE FOR THE IMPEACHMENT OF GOVERNOR ROBERT BENTLEY, THE JUDICIARY COMMITTEE. OF THE ALABAMA HOUSE OF REPRESENTATIVES (“THE COMMITTEE") HEREBY COMMANDS YOU: [To appear before the Committee and be questioned atthe place, date, and time specified below: Place Date Time: [To produce the materials, identified in the attached Exhibit A, to the Committee a the place, date, and time specified below: Place: 400 20" Stret North, Birmingham, Alubame 35203, Date: Monday, October 10,2016 ‘Time: By no later than 5:00 pan, (ON BEHALF OF THECOMMITTEE: ISSUED BY: Representative Mike Jones Jeffrey Woodard ‘Chairman, Alabama Huse Judiciary Committee Clerk, Alabama House of Representatives Date: Date ‘Any questions pertaining to this Subpoens should be directed to the Special Counsel for the: ‘Committe: Jackson R. Sharman Ill 400 20th Steet North Bimingham, Alabama 35203, ‘Telephone: (205) 981-0700 Email: jsharman@lighfootlav.com Page lof BEFORE THE JUDICIARY COMMITTEE OF THE ALABAMA HOUSE OF REPRESENTATIVES: TO: The Honorable Robert Beatley Governor of Alzbama ‘SUBPOENA clo Joseph C. Espy IIL, Esq. EXHIBIT A MeLtos, Esty & WILLIAMS, 255 Dexter Avenue ‘Montgomery, Alabama 36104 Defi ions and Instructions sour” a5 used herein refers to Governor Robert Bentley in his personal A. Theterm “you or eo B. Unless otherwise specified, al items shall encompass the time from January 17, 2011 to the present C. Documents responsive to any items shall be produced together, in electronic or paper folders or with other enclosures that separate the file by item number. Ifa document is responsive to ‘more than one item, it shall be produced in response othe item to which it is primarily respossive. ocuments and Things Requested 1. Allstatements for any checking, savings, or investment account in your name, jointly or individually. 2. All federal and state income tx returns, including all schedules, attachments, and W-2s, 3. Any andall documents, electronic data, and information evidencing or relating to any and all work, services, or ods performed for or provided tothe State of Alabama, Bentley for ‘Governor, Inc. or you by Rebekah Mason, RCM Communications, Ine. Jon Mason, or IRM. Enterprises, Inc. 4. Any andall documents, electron data, and information evidencing or relating to any ‘and all compensation, rimbursements, expenses, and payments of any kind made by the State of ‘Alabama, Bentley for Governor, Inc. or you or on your behalf to Rebekah Mason, RCM ‘Communications, In. Jon Mason, JRM Enterprises Inc, Alabams Couneil for Excellent ‘Government, or Bentley for Governor, In, 5. Any andall documents, electronic data, and information evidencing or elting vo your daily and weekly schedale 6. A.compkte list of any and all cellular phones or mobile devices owned or used by you, including for each phone or device the telephone number, account number, the name of the curier, and the dates of use or seve 7. _Allbillsand usage histories for any cellular phone or mobile device listed in response to the previous Request Page2 of 4 8, A-complete ist of any and all email accounts and social media accounts owned or used by you. 9, Any and all audio oF video recordings of any part of any telephone or ather conversations between you and Rebekah Mason, 10. Any and all documents eletronic data, and information evidencing or relating to any ‘communications, including but expressly not limited to letters, note, email, text messages, ard voice messages, between you and any ofthe following persons, including any attomey or other person acting for or on behalf of either you or them a. Rebekah Mason; b. Ton Mason; cc. Spenser Collier; 4. Stan Stabler; &— RayLewis; Cooper Shattuck. 1, Any and all documents, electronic data, and information evidencing or relating to any ‘communications, including but expresly not limited o leters, notes, emails, text messages, ad voice ‘messages, sent 1 or receive by you concerning: Spencer Collier; b. Rebeksh Mason; © Jon Mason; 4. Alabama Council for Excellent Government, & RCM Communications, Ine £ IRMEnterprises, Ines {8 Matt Hart, Mike Duffy, or any other person involved inthe investigation, indictment, prosecution, oral of former Alsbama Speaker ofthe House Mike Hubbard; 1h, Theinvestgation, indictment, prosecution, or trial of former Alabama Speaker ‘of the House Mike Hubbarc. 12, Any and all documents, electronic data, and information evidencing or relating to any meetings at which both youand Spencer Collier were present from January 1, 2014 to the present, 13. Any and all documents, electronic dats, and information evidencing or relating to any ‘meetings at which both you and Rebekah Mason were present. 14, Any and all documents, electronic data, and information evidencing or relating to any of the following: Page 3 of 4 Rebekah Mason; bon Mason; © RCM Communications, nes 4. IRM Enterprises, Ines © reimbursements to you by or from the State of Alabama, the National Governors ‘Association, the Republican Governors Association, or Bently for Governor, Ine: Alabama Council for Excellent Government 15. Any and all dscuments, electron data, and information evidencing or relating to any and all work, services, or goeds performed or provided by Rebekah Mason, RCM Communications, Inc, Jon Mason, or JRM Enterprises, Ine for or tothe State of Alabama, Governor Robert Bentley the Oflice ofthe Governor, the University of Alabama, Alabama Council for Excellent Government, of Bentley for Governor, Ine. 16. Any and all documents, electronic data, and information evidencing or relating to ‘Statements of Eeonomic Ine-ests filed by you withthe Alabame Ethics Commission. Page 4of4 BEFORE THE JUDICIARY COMMITTEE OF THE ALABAMA HOUSE OF REPRESENTATIVES, TO: Governor Robert Bentley Office of the Governor of Alabama SUBPOENA clo Ross H. Garber, Esq. SIIPMAN & GOODWIN LLP 1875 K. Stree, NW ‘Washington, D.C. 20006 David B. Byrne, Jr. Esq (Chief Legal Advisor Office of the Governor of Alabama State Capitol {600 Dexter Avenue ‘Montgomery, Alabama 36130 PURSUANT TO THE COMMITTEE RULES OF THE HOUSE JUDICIARY COMMITTEE FOR THE IMPEACHMENT OF GOVERNOR ROBERT BENTLEY, THE JUDICIARY COMMITTEE OF THE ALABAMA HOUSE OF REPRESENTATIVES (THE COMMITTEE") HEREBY COMMANDS YOU © Toappear befere the Committe and be questioned a the place, date, and time specified below Pace: Date Time © To produce the materials, identified in the attached Exhibit, to the Commitee atthe place, date, and time specified below: Place: 400 20" Steet North, Birmingham, Alubame 35203, Date: Monday, Ostaber 10,2016 Time: By shan $:00 pan, (ON BEHALF OF THE COMMITTEE: ISSUED BY: ‘Representative Mike ‘ones —___Teffrey Woodard (Chairman, Alabama House Judiciary Committee Clerk, Alabama House of Represeniatives Date: Date: Page | of? ‘Any questions peri ‘Committe: 1g to this Subpoena should be directed to the Special Counsel forthe Jackson R. Sharman It 400 20th Street North Birmingham, Alabama 35203 Telephone: (205) $81-0700 Ena: jsharman@lighyootlan.com Page 2of7 BEFORE THE JUDICIARY COMMITTEE. OF THE ALABAMA HOUSE OF REPRESENTATIVES TO: Governor Rotert Bentley Office of the Governor of Alabama ‘SUBPOENA clo Ross H. Garber, Esq. EXHIBIT A SHIPMAN & GooDwiN LLP 1895 K. Street, NW ‘Washington, D.C. 20006 David B. Byrre, Jr, Esq. Chief Legal Advisor Office ofthe Governor of Alabama 600 Dexter Avenue ‘Montgomery, Alabama 36130 Definitions and Instructions |A, The term “Office ofthe Governor” as used herein refers to Governor Robert Bentley in his “official capacity and all current or former members of Governor Robert Bentley's Staff, including but ‘expressly not limited those assigned tothe following offices: Executive Office, Chief of Staff and Deputy Chief of Staff, Legal Office, Communications Office, Legislative Office, Constituent Services Office, Scheduling Office, Appointments Oifice, Policy Office, Administration Offic, Office ofthe First Lady, and Governor's Mansion, This subpoena i directed tothe Office ofthe Governor as defined herein and shll be construed to inelude al documents or things inthe possession, custody, ot control of any and all persons encompassed by that erm. B. Unless otherw se specified, all itoms shall encompass the period of time beginning January 17, 2011 to the present ©. Documents responsive fo any items shall be produced together, in eletronic or paper file filers or with other enclosures that separate the ils by item number. Ifa document is responsive to ‘more than one item, it shall be produced in response to the item to which it is primarily sponsive. Ds ‘Things Requested |. All Stte employment policies applicable wo te Once of te Guvesner 2. Current and previous staff lists, the Office ofthe Governor. ectores, and organizational charts and diagrams for 3, Forallcurrent and former members ofthe Office of the Governor, list af their work telephone(s) and State-issued cellular telephone(s) and mobile device() 4, The complete calendar of Governor Robert Bentley in native electronic format, including any and all clectronie data and information evidencing or reflecting any chang:s made a any time thereto. Page 3 of 7 5, The complete calendar of Rebekah Mason in native electronic format, including any ‘and allelectronie data and information evidencing or reflecting any changes made t any time thereto 6. For the period oftime beginning January 1,013 to present, daily and weekly schedules ‘of Govemor Robert Bentley, including any and all documents evidencing or relating to any changes ‘made at any time thereto 7. Any andall documents, electronic dat, and information evidencing or relating to the use of State aircraft by, of at the direction of, the Office ofthe Governor, including but expressly not Timited to, all requests fr travel, light plans, ight logs, and flight manifests. 8, Any andall documents, electronic data, and information evidencing or relating to round transportation oo for Rebekah Mason, including but expressly not limited to all requests to “any State aeney, route plans, and vehicle manifests 9, Any andall documents, electronic data, and information evidencing or relating to any and all visits by Rebekah Mason to the Governor's Mansion and its appurtenant facilities. 10. Any andall documents, electronic data, and information evidencing or relating to any and all visits by Rebekah Mason to Wynfeld Estate and is appurtenant facilites. 11, Any andall documents, electronic data, and informstion evidencing or relating to leasing or chartering areraft for travel by Governor Robert Bentley or Rebekah Mason, 12, Any andall documents, electronic data, and information evidencing or relating to any requests for reimbursement from Slate funds, including ll supporting documentation, submited by or ‘on behalf of Governor Robert Bentley from January I, 2013 tthe presen, 13, Any andall documents, eletroni data, and information evidencing or relating to any requests for reimbursertent from State funds, including all supporting documentation, submited by or ‘on behalf of Rebekah Mason from January 1, 2013 tothe present. 14, Any andall documents, electronic data, and information evidencing or relating to any requests for reimbursenrent, including all supporting documentation, submitted tothe Nationel ‘Governors Association from January 1, 2013 to the present. 15, Any andall documents, electronic data, and information evidencing or relating to any requests for reimbursement, including all supporting documentation, submitted to the Repub ean Govemors Association from January 1, 2013 to the present 16. Any andall documents, electronic data, and information evidencing or relating o any requests for reimbursement, including all supporting documentation, submitted to Bentley for Governor, Ine. fom January 1, 2013 tothe present 17. Any andall documents, electronic data, and information evidencing or relating to any requests for reimbursement from State funds, including all supporting documentation, for any expense relating to Rebekah Mason submitted by or on behalf ofthe Office ofthe Governor from January 1, 2013 tothe present, 18. Any andall documents, electronic data, and information evidencing or relating to any and all work, services, or goods performed or provided by Rebekah Mason, RCM Communications, Inc, Jon Mason, or JRM Enterprises, Inc. fr or tothe State of Alabama, Governor Robert Bently, the Page 4 of 7 “Office of the Governor, the University of Alabama, Alabama Council for Excellent Government, Bentley for Governor, ine 19, Any and all documents, electron data and information evidencing or relating 0 any and all compensation, reimbursements, expenses, and payments of any kind to Rebekah Mason, RCM. ‘Communications Inc, Jon Mason, or RM Enterprises, In. 20, Any and all documents, electronic data, and information evidencing or relating o any nondisclosure or confidentiality agreements signed by or proffered to any person by or on behalf ofthe Office ofthe Governor 21, Any and all documents, electronic data, and information evidencing or relating any and al temporary or permanent removals, reassignment, replacements, of terminations of any persons inthe Office ofthe Governor. 22, Any and all documents, electronic data, and information evidencing or relating any and all temporary or permatent removals, eassigaments, replacements, or terminations of any officers ‘or employees of the Alabama Law Enforcement Agency ot any of its subordinate agencies, departments, or divisions from January 1, 2014 to present 23, Any and all documents, electronic data and information evidencing or relating to any formal or informal files maintained, whether electronically or otherwise, by or within the Office of the ‘Governor related to any ofthe following: a. Spenser Collier b. Rebekah Mason: Jon Mason; Diane Bentleys Bentley for Governor nes £. Alabama Council for Excellent Goverment; s — RCM Communications, Ines he IRMEnterprises nes i. MattHart, Mike Duffy, or any other person involved inthe investigation, inaietmen, prosecution, oral of former Alabuma Speaker of dhe House Mike Hubbard the investigation, indictment, prosecution, or til of former Alabama Sseaker of the House Mike Hubbard. 24. Any and all documents, electronic dat, and information evidencing or relating co the job titles, duties, or performance of Rebekah Mason. 25. Rebekah Meson’s personnel file 26, A list of any and all email accounts used by Governor Robert Bentley Page S of? 27, list of any and all email accounts used by Rebekah Mason. 28, Anelecttonie copy in native format of any and all email accounts signed or used by ‘Rebeka Mason, 29. Acomplete list of any and all cellular phones or mobile devices issued to or used by ‘Govemot Robert Bentley, inluding foreach phone or device the telephone number, secount number, ‘the name ofthe carter, and dates of use or sevice. 530. _Allbills and usage histories for any cellular phone or mobile device listed in response to the previous Request. 31. A-complete list oF any and all cellular phones or mobile devices issued to or used by Rebekah Mason, including foreach phone or device the telephone number, acount number, the name ofthe carrer, and dates of use or service. 32. _Allbills and usage histories for any cellular phone or mobile device listed in response to the previous Request. 33, Any and all documents, electronic data, and information evidencing or relating to any ‘communications, including but expressly not limited to letters, notes, emails, text messages, and voice ‘messages, between Governor Robert Bentley and Rebekah Mason, including any atlomey or other person acting fororon behalf of either of them. 34, Any and all documents, eletronie data, and information evidencing o relating to any ‘communications including but expressly not imited to letters, notes, emails, text messages, and voice messages, between Governor Robert Bentley and Jon Mason, including any atomey or ther person ‘acting for or on tehalf of either of them. 35. Any and all audio of video recordings of any part of any telephone o other conversations beween Governor Robert Bentley and Rebekah Mason, 36. Any and all documents, electronic data, and information evidencing or relating to any meetings at which both Governor Robert Bentley and Spencer Collier were present fom January 1, 2014 to the present. 37. Any and all documents, electronic data, and information evidencing or relating to any ‘meetings at which both Governor Robert Bentley and Rebekah Mason were present. 38, Any andall documents, electronic data, and information evidencing ot relating to any ‘communications including but expressly not limited to letters, notes, emails, text messages, and voice ‘messages, between the Office of the Governor and Spencer Colle, including any atorney or other person acting for or on behalf of either of them, from January 1, 2014 to present. 39, Any and all documents, electronic dat, and information evidencing or relating to any ‘communications including but expresly not imited to letes, notes, emails text messages, and voice ‘messages, between the Office ofthe Governor and Stan Stabler, including any attomey or other person acting for or on behalf of either of them, from January 1, 2014 to present. 40. Any and all documents, electronic data, and information evidencing or relating to any ‘communications including but expressly not limited to leters, notes, emails, text messages, and voice Page 6 07 messages, between the Office ofthe Governor and Ray Lewis, including any attorney or other person acting for or on behalf of either of them, from January 1, 2014 to presen. 41. Anyand all documents, electronic data, and information evidencing or eating in any ‘way tothe substance ofthe oess release by the Office of the Governor on March 22, 2016 (ich is tached hereto as Attachment 1, including but expressly not limited to 4 placiag Spencer Collier on medical leaves, 1b. internal review ofthe Alabama Law Enforcement Agency or any ofits subontinate agencies, deparments or divisions; ‘e. _misuse of State funds by the Alabama Law Enforcement Agency or any ofits subordinate agencies departments or divisions; 4. termination of Spencer Collier. 42, Any and al documents, electronic data, and information evidencing or relating to the Alabama Council for Excelent Government, 43, Any and all documents, electronic data, and information evidencing or relating to the investigation, indictment, prosecution, or trial of former Alabama Speaker ofthe House Mike Hubbard 44, Any and all documents, electronic data and information evidencing o relating tothe 2014 gubematoral campaign, including but expressly not limited to Bentley for Governor, inc. 45, Any and all documents, electronic data, and information evidencing or relating to ‘Statements of Eeonomic Interests filed by the Office of the Governor withthe Alabama Ethics Commission. 46, Any and all documents, electronic data, and information evidencing or relating to any ‘communications, including but expressly not Fimited to letters, notes, emails, text messages, and voice ‘messages, sent or received by the Office ofthe Governor concerning: Rebekah Mason; b, Alahuma Council for Excellent Government; «REM Communications, Ine. 6. SRMEnerprises nes © Bentey for Governor, Ine Page 7 0f 7 the Office of Alabama Governor Robert Bentley Governor Bentley Announces Termination of Spencer Collier as Alabama Law Enforcement Agency Secretary March 22, 2016 ‘Press Releases: MONTGOMERY ~Govermor Robert Bente on Tuesday announced the termination of Alabama Law Enforcement Agency Secretary Spencer Colle effective immediatly. ‘Spencer Coller and Ihave served tether long ina, dang back to my time nthe Alabama House of Representatives” Governor Henley eid "Hee a rend of mune, and led the implementation ofthe Consliationef ate lee enforcement functions into one singe agency, the Alabama Law Enforcement ‘Agency (ALES), apprecite Spencer's service to theStat of Alabama “After plain Spencer on medial save afew week ag to allow hm to rcover from back surgery, Acting [ALEA Secretary San Stabler idented several ares of concen in the operations elices ad procedares ‘ALEA. Afra intemal review the ALEA Integrty Unit ound a number of sous, ineiuding posible ‘misuse of state fur Iam dlsapponted to ean these facts, and today, eioved Spencer Cole of his ‘tie as ALEA Serer.” Governor Berley als announced the appointment of Stan Stabler to serve as Secretary of ALEA, “Sian Stables a veteran aw enforcement officer who has 30 plas years inlaw enforcement, Lappreciate -iscorvice Acting Secretary and cannot hk of a ore lif person to serve as ALEA Secretary] pres Stn joining my tem to lead the dedicate men and women who respond when Alabarians cll mthem in emergencies,” Bene added, roid byte Offi th Governor of Albom | geersralaona goo ATTACHMENT 1 [BEFORE THE JUDICIARY COMMITTEE. OF THE ALABAMA HOUSE OF REPRESENTATIVES “0: Benth or Geren | vinhete yt B. suorna Murotrsm & wins Pe Meare Aone Hwtemer haa 3610 PURSUANT TO THE COMMITTEE RULES OF THE HOUSE JUDICIARY COMMITTEE FOR THE IMPEACHMENT OF GOVERNOR ROBERT BENTLEY, THE JUDICIARY COMMITTEE OF THE ALABAMA HOUSE OF REPRESENTATIVES (“THE COMMITTEE") HEREBY COMMANDS YOU _Toappear befere the Committee and be questioned atthe place, date, and time specified below: Place: Date: Time: [To produce the materials, identified in the attached Exh date, and time specified below: to the Commits at the pl Place: 400 20" Street North, Bi 5203 Date: Monday, October 10, ‘Time: By no later than 5:00 pm, (ON BEHALF OF THE COMMITTEE: ISSUED BY, ‘Representative Mike Jones Jefirey Woodard Chairman, Alabama House Judiciary Committee Clerc, Alnhama House of Representatives Date: Date ‘Any questions pertaining to this Subpoena should be directed to the Special Counsel forthe Committe: Jackson R. Sharman TIL 400 20th Street North Birmingham, Alabama 35203 Telephone: (205) 581-0700 Exmail:jsharman(@lightfootlaw.com Page I of 4 BEFORE THE JUDICIARY COMMITTEE (OF THE ALABAMA HOUSE OF REPRESENTATIVES, Bentley for Governor, Ine. clo Joseph C. Espy If, Esq. SUBPOENA MELTON, EsPy & WILLIAMS, P.C. EXHIBIT A 255 Dexter Avenue Montgomery, Alabama 36104 Definitions and Instructions A, Theterm “Office ofthe Governor” as used herein refers to Governor Robert Bentley ir his official capacity and all current or former members of Governor Robert Bentley's Staff, inclucing but expressly not limited to those assigned tothe following offices: Executive Office, Chief of Staff and Deputy Chief of Staff, Legal Office, Communications Office, Legislative Oifice, Constituent Services Office, Scheduling Office, Appointments Office, Poliey Office, Administration Office, Office of the First Lady, and Governor's Mansion. B. Documents responsive to any items shall be produced together, in electronic or paper file folders or with other enclosares that separate the files by item number. If document is respoasive to ‘more than one iter, it shall be produced in response to the item to which i is primarily responsive, Documents and Thin 1. Any and all documents Bentley for Governor, nc. has ever submitted to the Seoetary of State of Alabama, without time limitation, ineluding but expressly not limited to certificate(s) of name reservation aces of incorporation, and verticate(s) uf farmation, 2, Bentley for Governor, nc.s articles of incorporation, bylaws, and all amendments to bylaws 3, Minutes forany meetings of Bentley for Govemor, Inc.'s shareholders and directors, 4. Any and all documents Bentley for Governor, Ine. has ever submited tothe Infernal Revenue Service and the Alabama Department of Revenue, together with all related schedules and attachments, 5. All federal and state tax returns, including all schedules and attachments, from Bentley {for Governor, Inc's formation to the present 6. complete ist of all of Bentley for Governor, Ine's dtectos, stockholders, officers and employees, including ther ttle and contact information, and organizational chars or diagrams showing the relationships between and among all such persons. 7. Any and all ocuments filed with any agency of the State of Alabama, including but ‘expressly not limited to any documents filed pursuant to the Alabama Fair Campaign Practices Act, Page 2 of 4 8, Any and all documents, electronic data, and information evidencing or relaing to any and all donations, contributions, compensation, reimbursement, or other payments of any kiné made to [Bentley for Governor, Ine, by the State of Alabama, the Office ofthe Governor, Rebekah Mason, Jon Mason, the University of Alabama, the Alabama Council for Excellent Government, RCM Communications, In, JRM Enterprises, In., or Governor Robert Bentley in his personal capacity 9. Any and all documents, electron data, and information evidencing ot relating to any ‘and all compensation, reinbursements, expenses, and payments of any kind by Bentley fee Governor, Inc tothe State of Alabama, the Office ofthe Governor, Rebekah Mason, Jon Mason, the Alsbama Council for Excellent Government, RCM Communications, Inc, JRM Enterprises, In, or Governor Robert Bentley in his personal capacity 10, Any and al documents, electronic data, and information evidencing or relaing to any communications, including but expresély not limited to letters, notes, emails, text messages, and voice messages, between any of Bentley for Governor, In.'s director, officers, and employees and any of the following persons, inc uding any attorney or other person acting for or on behalf of either Bentley {for Govemor, Ine. or them: _Retcksh Mason; b. Jon Mason; Spencer Collier; 2 Stan Stabler; fe RayLewis; £ any director, officer, employee, agent, or representative of RCM ‘Communications Ine. ‘& _any director, officer, employee, agent, or representative of JRM Enterprises, Ine; h, any director, officer, employee, agent, or representative of Alabama Council for Excellent Government. 11, Any and al documents, electronic data, and information evidencing or reiting to any communications, ineluding but expressly not limited to letes, notes, emails text messages, and voice messages, sent of received by any of Bentley for Governor, Inc.'s directors, officers, and employees concerning: a, Rebekah Mason; b.JonMason; Spencer Collier; Stan Stabler; RayLewis: RCM Communications, Ine; Page 3 of 4 2. the following 13, . IRMEnterprises, Ines Alabama Council for Excellent Government; i. State aera; |. Matt Hart, Mike Duffy, or any other person involved inthe investigation, indictment, prosecution o ral of former Alabama Speaker ofthe House Mike Hubbard; k. the investigation, indictment, prosecution, or trial of former Alabama Speaker of the House Mike Hubbard [Any and all documents, electron data and information evidencing or relating to any of 8 Rebeksh Mason: bon Mason; © Spencer Collier 4. Stan Stabler: & RayLewis; £. RCM Communications, Ines IRM Enterprises, Ines 1. Alabama Council for Excellent Government 4. State aircrat; |. Mate Hart, Mike Daffy, or any other person involved in the investigation, indictment, prosecution, or trial of former Alabama Speaker ofthe Howse Mike Hubbard; the investigation, indictment, prosecution, or tial of former Alabama Speaker of the House Mike Hubbard. ‘Any and alt documents, electronic data information, oF other things that you believe are relevant, in any way, to the proposed Articles of Impeachment Against Governor Bentley, acopy of ‘whieh is enclosed as Attachment 1, or the investigation pertaining thereto. Page 4 of 4 R367 176360-2 by Representatives Henry, Whorton (I), Sessions, Balt, Patterson, Hanes, Whorton (R), Holmes (Wt), Standridge, Noore (B), Crawford, Farley, Williams (JW), Ainsworth, Ford, Todd, Wilcox, Butler, Nordgren, Wii ams (®), Morrow, Ingrem and Mooney RFD: Judiciary First Read: 28-APR-16 Page 0 ATTACHMENT 1 10 u 2 3 as 16 uv 18 a9 20 2 22 23 24 25 26 176360-2:n:04/27/2016:I87/th LRS2016-1344R1 ARTICLES OF IMPEACHMENT AGAINST GOVERNOR BENTLEY. WHEREAS, in 2010, Governor Bentley was elected the 53rd Governor of the State of Alabama and was reelected to a second term in 2014; and WHEREAS, Section 173 of the Constitution of Alabama of 1901 provides that the Governor and other constitutional officers of this state may be impeached upon the adoption of articles of impeachment by this bedy and upon trial by the Senate, acting as a court of impeachment; and WHEREAS, two formal complaints have been filed with the Alabama Ethics Commission to determine whether Governor Bentley violated state ethics laws by misusing state property; aud WHEREAS, in recognition of the gravity of the adoption of these articles of impeachment and upon findings that Governor Bentley has violated the public trust, this body concludes Governor Bentley should be impeached for cause; now therefore, Page 1 ATTACHMENT I nu a 13 u 18 16 re 18 a9 20 BE I? RESOLVED BY THE HOUSE OF REPRESENTATIVES OF THE LEGISLATURE OF ALABAMA, That Governor Bentley is impeached for cause and that the following articles of impeachment, based upon the findings in this resolution, be transmitted te the Senate for trial as provided in Section 173 of the Constitution of Alsbama of 1901: ARTICLE 1. Wiligul Neglect of Duty. Credible evidence exists to create probable cause to believe that, in his conduct while Governor of the State of Alabama, he willfully neglected his duty as Governor by failing to faithfully execute the laws of this state and by refusing to perform hie constitutional and statutory duties. ARTICLE I corruption in Office Credible evidence exists to create probable cause believe that, in his conduct while Governor of the State of Alabama, he unlawfully misused state property, misappropriated state resources, and consistently acted in violation of law promote his on personal agenda. Page 2 ATTACHMENT 1 BEFORE THE JUDICIARY COMMITTEE OF THE ALABAMA HOUSE OF REPRESENTATIVES ‘TO: Mr. Michael H. Echols ‘lo Hon. R. Bernard Harwood, Jr. SUBPOENA Rose Harwooo 2200 Jack Warner Parkway, Ste. 200 ‘Tuscaloosa, Alabama 35401 PURSUANT TO THE COMMITTEE RULES OF THE HOUSE JUDICIARY COMMITTEE FOR THE IMPEACHMENT OF GOVERNOR ROBERT BENTLEY, THE JUDICIARY COMMITTEE. OF THE ALABAMA HOUSE OF REPRESENTATIVES (“THE COMMITTEE”) HEREBY COMMANDS YOU: —Tosppearbelore the Committee and be questioned at the place, date, and time specified below: Place: Date: Time: 2 To produce the materials, identified inthe attached Exhibit A, to the Committe atthe place, date, and time specified below: Place: 400 20" Street North, Birmingham, Alabama 35203 Date: Monday, October 10,2016 ‘Time: By no later than $:00 pm, ON BEHALF OF THE COMMITTEE: ISSUED BY. Representative Mike Jones Jeffrey Woodard i Chairman, Alabama House Judiciary Committee Clerk, Alabama House of Representatives vate: Date ‘Any questions pertaining to this Subpoena should be directed to the Special Counsel forthe Committe: Jackson R. Sharman IIL 400 20th Streot North Birmingham, Alabama 35203 ‘Telephone: (205) 381-0700 Email jsharman@ligitfootlaw.com Page | of + BEFORE THE JUDICIARY COMMITTEE. OF THE ALABAMA HOUSE OF REPRESENTATIVES | TO: Mr. Michael H. Echols clo Hon. 8. Bernard Harwood, Jr. SUBPOENA ROSEN Hanwoop EXHIBIT 4 2200 Jack Warner Parkway, Ste, 200 ‘Tuscaloosa, Alabama 35401 Definitions and Instructions A. ‘The term “Office ofthe Governor” as used herein refers to Governor Robert Bentley in his ‘official capacity and all current or former members of Governor Robert Bentley's Saf including but ‘expressly not limited to those assigned tothe following offices: Executive Office, Chief of Staff and Deputy Chief of Staff, Legal Office, Communications Office, Legislative Office, Constituent Services Office, Schedulirg Office, Appointments Office, Policy Office, Administration Office, Office ofthe First Lady, and Governor's Mansion. B, Unless otherwise specified, al items shall encompass the period of time begining January 17, 2011 to the preset. ©. Documents responsive to any items shall be produced together, in eletronic or paper fle folders or with ofner enclosures that separate the files by item number. Ifa document is tesponsive to ‘more than one item, it shall be produced in response to the item to which it is primarily responsive. Dosuments and Things Requested 1. Any and all documents, eletronic data, and information evidencing ar relating to any and all work, services, or goods performed or provided by you for ort the Alabams Couneil for Excellent Goversment; RCM Communications, Inc, JRM Enterprises, In. Bentley for Governor, Inc., Governor Rabert Bentley in his personal capacity, or Rebekah Mason, from January 1.2014 to the present 2. Aay and all documents, electronic data, and information evidencing or relating to any and all ompensstion, reimbursements, expenses, and payments of any kind made to Bentley for Governor, Inc bs the State of Alabama, the Office of the Governor, Rebekah Mason, Jon Mason, the ‘Alabama Couneil for Excelent Gavernment, RCM Communications, In, JRM Encerprises, Inc, oF Governor Robert Bentley in his personal capacity 3, Aay and all documents, electronic data, and information evidencing or relating to any and all compenssion, reimbursements, expenses, and payments of any kind made by Bentley for Governor, Ine othe State of Alabama, the Offic ofthe Governor, Rebekah Mason, Jon Mason, the Alabama Council for Excellent Government, RCM Communications Ine., JRM Enierprises, Inc. of Governor Robert Bentley in his personal capacity 4, Any and all documents, electronic data and information evidencing or relating to any and all compensetion, reimbursements, expenses, and payments of any kind made tthe Alabama Page 2 of 4 CCouneil for Excellent Government by the State of Alabama, the Office ofthe Governor, Rebekah Mason, Jon Mason, Bentley for Governor, Inc, RCM Communication, Ine.,JRM Enterprises, Inc, of Govemor Robert Bentley in his personal capacity. 5, Any and all documents, electronic data, and information evidencing or relating o any and all compensation, reimbursements, expenses, and payments of any kind made by the Alabama Council for Excellent Government othe State of Alabama, the Office of the Governor, Rebekah ‘Mason, Jon Mason, Bent ey for Governor, Inc.,. RCM Communications, ine., IRM Enerprises, Ine. or Governor Robert Bently in his personal capacity 6. Any and all documents, electronic data, and information evidencing orrelatng to any ‘compensation, loans, gifs, payments, oF other transfers of money or things of value between Governor Robert Bentley in is personal capacity and Rebekah Mason, 7. Any andall notes, memoranda, analysis, summaries, or compilations o’ records, prepared or maintained by you, solely of working with others, relating tothe financial activity oF tonduct of Governor Rokert Bentley in either his official or personal capacity 8, Any and.ll documents, electronic data, and information evidencing orrelatng to any ‘communications, including but expressly not limited to letters, notes, emails, text messages, and voice messages, etween you and any ofthe following persons, including any attorney or oher person acting for oF on behalf of either you others: 8. the fice of the Governor; b. Governor Robert Bentley in is personal capacity; © Dianne Bentleys, Rebekah Mason; Jen Mason; £ any director, officer, employee, agent, or representative of Alabama Council for Excellent Government; any director, officer, employee, agent, or representative of Bemley for Governor, Ines hh. any dicector, officer, employee, agent, or representative of RCM. (Communications, Ines i, any director, officer, employee, agent, or representative of IRM Enterprises, Ine. 9, Any and.ll documents, electronic dat, and information evidencing ot relating t0 any communications, including but expressly not limited to letters, note, emails, text messages, and voice messages, between you and any person, whether sent by you, sent to you, or copied to you, concerning a. the Offce of the Governor; b, Governor Robert Bentley in his personal capacity © Dianne Bentley; Page 3 of 4 10. the following: 1 4, Rebekah Mason: ©. Bentley for Governor, Ine; f. Alabama Council for Excellent Government; 8 RCMCommunications, Ines bh, JRMEnterprises, Ine. ‘Any and all documents, eletronic data, and information evidencing or relating to any of & the Office ofthe Governor; Rebekah Mason; ¢. Alabama Coun for Excelent Government 4. Bently for Governor, nes REM Communications, Ie £SRMEDterprises, Inc Any and all documents, electronic data information, or other things that you believe are relevant, in any way, tothe proposed Articles of Impeachment Against Governor Bentley, 2 copy of ‘which i enclosed as Attachment 1, or the investigation pertaining thereto. Page 4 of 4 R367 176360-2 By Representatives Henry, Whorton (I), Sessions, Ball, Patterson, Hanes, Whorton (R), Holmes (M), Standridge, Moore (B), Ceawford, Farley, Willians (JW), Ainsworth, Ford, Todd, Wilcox, Butler, Nordgren, Williams (P), Morrow, Ingram and Mooney RED: Judiciary First Read: 28-APR-16 Page 0 ATTACHMENT | 10 rr 2 aa a4 as 16 uy rr 19 20 a 22 23 24 25 26 176360-2 4/27/2016: ARTICLES OF IMPEACHMENT AGAINST GOVERNOR BENTLEY. WHEREAS, in 2010, Governor Bentley was elected the 53rd Governor of the State of Alabama and was reelected to a second term in 2014; and WHEREAS, Section 173 of the Constitution of Alabama of 1901 provides that the Governor and other constitutional officers of this state may be impeached upon the adoption of articles of impeachment by this body and upon trial by the Senate, acting as a court of impeachment; and WHEREAS, two formal complaints have been filed with ‘the Alabama Ethics Commission to determine whether Governor Bentley violated state ethics laws by misusing state property and WHEREAS, in recognition of the gravity of the adoption of these articles of impeachment and upon findings that Governor Bentley has violated the public trust, this body concludes Governor Bentley should be impeached for cause? now therefore, Page 1 ATTACHMENT u Fa a a a5 16 re 18 a 20 BE TT RESOLVED BY THE HOUSE OF REPRESENTATIVES OF THE LEGISLATURE OF ALABAMA, That Governor Bentley is impeached for cause and that the following articles of impeachment, based upon the findings in this resolution, be transmitted to the Senate for trial as provided in Section 173 of the Constitution of Alabama of 1901: ARTICLE 1. WiLLEul Neglect of boty, Credible evidence exists create probable cause to believe that, in his conduct while Governor of the State of Alabama, he willfully neglected his duty as Governor by failing to faithfully execute the laws of this state and by refusing to perform his constitutional and statutory duties. aRrrce 11. corruption in office. Credible evidence exists to czeate probable cause to believe that, in hie conduct while Governor of the State of Alabama, he unlawfully misused state property, misappropriated state resources, and consistently acted in violation of law to promote his on personal agenda Page 2 ATTACHMENT 1 BEFORE THE JUDICIARY COMMITTEE (OF THE ALABAMA HOUSE OF REPRESENTATIVES, TO: Mr. Jonathan Mason clo Robert D. Segall, Esq. SUBPOENA ‘COPELAND, FRANCO, SCREWS & GILL 444 South Perry Street Montgomery, Alabama 36104 PURSUANT TO THE COMMITTEE RULES OF THE HOUSE JUDICIARY COMMITTEE. FOR THE IMPEACHMENT OF GOVERNOR ROBERT BENTLEY, THE JUDICIARY COMMITTEE OF THE ALABAMA HOUSE OF REPRESENTATIVES (“THE COMMITTEE") HEREBY COMMANDS YOU ied below: D_Toappearbefite the Committee and be questioned atthe place, te, and time spe Place Date: Time: 2 To produce the materials, identified in the attached Exhibit A, to the Committe at the place, date, and time specified below: Place: 400-20" Strest North, Birmingham, Alabama 35203 Date ber 10,2016 Time: By no later than $:00 pam, (ON BEHALF OF THE COMMITTEE: ISSUED BY: Representative Mike ‘ones Iefftey Woodard Z ‘Chairman, Alabama House Judiciary Committee Clerk, Alaharna House of Repeesentives Date: Date: Any questions pertaining t0 Committe: is Subpoena should be directed to the Special Counsel forthe: Jackson R. Sharman IL +400 20th Stet North Birmingham, Alabama 35203 Telephone: (205) 581-0700 Enuil:jsharman@@lightfootlaw.com Page 1 of BEFORE THE JUDICIARY COMMITTEE. OF THE ALABAMA HOUSE OF REPRESENTATIVES TO: Mr. Jonathan Mason clo Robert D. Segall, Esq. SUBPOENA ‘COPELAND, FRANCO, SCREWS & GILL EXHIBIT A, 444 South Perry Street ‘Montgomery, Alabama 36104 fi sand Tnstru A. ‘The term “Office of the Governor” as used herein refers to Governor Robert Bentley in his “official capacity and all current or former members of Governor Robert Bentley's Sta, including but expressly not limited to those assigned tothe following offices: Executive Office, Chief of Sut and Deputy Chief of Staff, Legal Office, Communications Office, Legislative Office, Constituent Services Office, Scheduling Oitize, Appointments Office, Policy Office, Administration Office, Office of the First Lady, and Governor's Mansion. B. Unless otherwise specified, all items shall encompass the period of time beginning January 17, 2011 to the present ©. Documents responsive fo any items shal be produced together, n electronic ot paper fle folders or with othe enclosures that separate the files by item number, Ifa document is respcnsive to ‘more than one item, it shall be produced in response tothe item to which iis primarily responsive, Documents and Things Requested! |. Any andall documents, eletronic data and information evidencing o relating to any and all work, services, or oods you performed for or provided tothe State of Alabama, the Oice of the Goverar, the Univrsity of Alabama, the Alabama Council for Excellent Government, RCM ‘Communications, Ine., RM Enterprises, Ine., Bentley for Governor, Ine., or Governor Rober, Bentley inhis personal capacity 2. Any andall documents, electronic dat, and information evidencing or relating to any and all donations, contibutions, compensation, reimbursements, or other payments of any kind made to you by the State of Alabama, the Office ofthe Governor, the University of Alabama, the Alabama ‘Council for Excellent Government, RCM Communications, Inc., JRM Enterprises, In. or Bentley for Governor, Ine. 3. Any andall documents, electronic data, and information evidencing or relating o any ‘and all compensation, reimbursements, expenses, and payments of any kind made by you tote State ‘of Alabama, the Office ofthe Governor, the University of Alabama, the Alabama Council for Excellent Government, RCM Communications, Inc, JRM Enterprises, Ine. or Bentley for Governor, Inc. 4. Any ane all documents, electrani data, and information evidencing or relating to any loans gifts, payments or other transfers of money or things of valve to you from of on behalf of Governor Robert Bently in his personal capacity. Page 2 of S 5. _Allstatemens for any checking, savings, or investment account into which, o¢ trom ‘whieh, any ofthe compensation, reimbursement, expenses loans, gilts, payments, or other transfers of ‘money of things of value erred to in Requests 2 through 4 were deposited or withdrawn, 6. Any and all documents, electronic data, and information evidencing or relating to any requests for reimbursement ftom State funds, including all supporting documentation, submited by {yot or on your behalf from Ianuary 1, 2013 fo the present. 7. Any andall documents, electronic data, and information evideneing or relating to your _job titles, utes, or performance with o fr the State of Alabama, Bentley for Governor, Inc. ot the 2014 gubematoral eampaign of Governor Robert Bentley. 8. Any and all documents, electronic data, and information evidencing or relating o any nondisclosure or confidentiality agreements signed by you or proffered to you by or on behalf of | Governor Robert Bentley, in his personal capacity, or the Office ofthe Governor. 9. complete list of any and all email accounts and socal medi accounts owned or used by you. 10, Any and all documents, eleetroni dat, and information evidencing or relating to State business. 11. Any and all documents, electronic data and information evidencing or elatingto any ‘communications, including but expresly not limited to letes, notes, emails text messages, and voice messages, between you andany ofthe following persons, including any attorney or other person acting for or on behalf of ether yeu or them: 4, the Office ofthe Governor; b. Governor Robert Bentley in his personal capacity; © Dianne Bentleys 4d. any aher member ofthe Bentley family: e. Spencer Collier; f Stan Stabler: s RayLewis; any director, officer, employee, agent, or representative of RCM. ‘Communications, Ine i, any director, officer, employee, agent, or representative of Alabama Caunei! for Excelent Government; ik any director, officer, employee, agent, or representative of Bently for Governor, Ine. 12. Any and all documents, cletronic data, and information evidencing or relating to any ‘communications, including but expressly not limited t eters, notes, emails, text messages, and voice ‘messages, sent 1 of received by you concerning Page 3 ofS 13 the folowing: 4. Ge Ofice ofthe Governor; . Covernor Robert Bentley in his personal capacity; © ianne Bently; 4. ayer member of the Bently familys Spencer Collier fan Suber: 8 RayLewis: 1h. Alabama Council for Excelent Government i. RCM Communications, Ines j. RRM Enterprises, nes k. Bentley for Governor, nes |, Alabame Law Enforcement Agency or any ofits subordinate agencies, departments, or divisions; im Sate raft 1h. Matt Hart, Mike Dufly, or any other person involved in the investigatien, indictment, prosecution, oral of former Alabama Speaker ofthe House Mike Hibbard; 0. the investigation, indictment, prosecution, or tral of former Alabama Speaker of the House Mike Hubbard, [Any andall documents, eletronic data, and information evidencing or relating to any of 4. the Office ofthe Governor b. Governor Robert Bentley in his personal capacity © Dianne Bentleys 4. any other member ofthe Bealey faily; © Spencer Collier, f REM Communi ions, Ine Alabama Council for Excellent Government, h. Bentley for Governor, Ines i. State aireran; Page4 of S| ik Mat Hart, Mike Duffy, or any other person involved in the investigation, indiciment, prosecution, or tral of former Alabama Speaker ofthe House Mike Hubbard; k.theinvestigation, indictment, prosecution, or trial of former Alabama Speaker of the House Mike Hubbard 14, Any and ell audio or video recordings of any part of any telephone or other ‘conversations between you and Robert Bentley. 15, _Any and sll documents, electronic dat and information evidencing or relating to Statements of Eeonomic Interests filed by you with the Alabama Ethics Commission 16, Any and sll documents, electronic dat, information, or other things that you believe are relevant, in any way, to tte proposed Anicles of Impeachment Against Governor Bentley, a copy of which is enclosed as Attchment I, or the investigation pertaining thereto. Page Sof 5 R367 176360-2 By Representatives Henry, Whorton (1), Sessions, Bail, Patterson, Hanes, Whorton (R), Holmes (i), Standridge, Moore (®), Crawford, Farley, Williams (JW), Ainsworth, Ford, Todd, Wilcox, Butler, Nordgren, Williams (P), Morrow, Ingram and Mooney RFD: Judiciary Firet Read: 28-APR-16 Page 0 ATTACHMENT I 16 a 18 as 20 22 23 24 28 26 04/27/2016:JB9/th LRS2016-1344R1 ARTICLES OF IMPEACHMENT AGAINST GOVERNOR BENTLEY. WHEREAS, in 2010, Governor Bentley wae elected the 5 d Governor of the State of Alabana and was reelected to a second term in 2014; and WHEREAS, Section 173 of the Constitution of Alabana of 1901 provides that the Governor and other constitutional officers of this state may be impeached upon the adoption of articles of impeachment by this body and upon trial by the Senate, acting as a court of inpeachnents and WHEREAS, two formal complaints have been filed with the Alabama Ethics Connission to determine whether Governor Bentley violated state ethics laws by misusing state property: WHEREAS, in recognition of the gravity of the adoption of these articles of impeachment and upon findings ‘that Governor Bentley has violated the public trust, this body concludes Governor Bentley should be impeached for cause; now therefore, Page 1 ‘ATTACHMENT | 20 a 2 a3 aa 16 uw 18 19 20 BE IT RESOLVED BY THE HOUSE OF REPRESENTATIVES OF THE LEGISLATURE OF ALABAMA, That Governor Bentley is impeached for cause and that the following articles of impeachment, based upon the findings in this resolution, be transmitted to the Senate for trial as provided in Section 173 of the Constitution of Alabama of 190: ARTICLE T Willful Neglect of Duty. Credible evidence exists to create probable cause to believe that, in his conduct while Governor of the state of Alabama, he willfully neglected hie duty as Governor by failing to faithfully execute the laws of this state and by refusing to perform his constitutional and statutory duties. ARTICLE 11. corruption in office. Credible evidence exists to create probable cause to believe that, in his conduct while Governor of the State of Alabama, he unlawfully mioused state property, misappropriated state resources, and consistently acted in violation of lew te promote his own pereonal agenda Page 2 ATTACHMENT 1 BEFORE THE JUDICIARY COMMITTEE OF THE ALABAMA HOUSE OF REPRESENTATIVES, TO: Mrs. Rebekah Mason clo Robert D. Sezall, sq. SUBPOENA COPELAND, FRANCO, SCREWS & GILL «444 South Perry Street Montgomery, Akibama 36104 PURSUANT TO THE COMMITTEE RULES OF THE HOUSE JUDICIARY ‘COMMITTEE FOR THE IMPEACHMENT OF GOVERNOR ROBERT BENTLEY, THE JUDICIARY COMMITTEE OF THE ALABAMA HOUSE OF REPRESENTATIVES (*THE ‘COMMITTEE”) HEREBY COMMANDS YOU: [__Toappear before the Committee and be questioned a the place, date, and time specified below: Place Date: Time: © To produce the materials, identified in the attached Exhibit A, to the Committee atthe pace, ate, and time specified below: Place: 400 20" Street North, Birmingham, Alsbama 35203 Date: Monday, October 10,2016 Time: By no later than 5:00 pm ‘ON BEHALF OF THE COMMITTEE: ISSUED BY: ‘Representative Mike Jo Tefirey Woodard ‘Chairman, Alabama House Judiciary Committee Clerk, Alabama House of Representatives Date: Date: Any questions pertaining to this Subpoens should be directed tothe Special Counsel for the ‘Commie: Jackson R. Sharman IIL 400 20th Street North Birmingham, Alabama 35203 ‘Telephone: (205) $81-0700 Email jsharmant@lightfottew:com Page 10f5 BEFORE THE JUDICIARY COMMITTEE OF THE ALABAMA HOUSE OF REPRESENTATIVES, TO: Mrs, Rebekah Mason ‘lo Robert D. Segall, Esq. SUBPOENA. COPELAND, FRANCO, SCREWS & GIL EXHIBIT A 444 South Perry Street Montgomery, Alabama 36104 Definitions and Instructions A. The term “Office ofthe Governor” as used herein refers to Governor Robert Bentley in his “official capacity an all current of former members of Governor Robert Bentley's Staf, including but “expressly not limited to those assigned to the following offices: Executive Office, Chietof Staff ard Deputy Chief of Staff, Legal Office, Communications Office, Legislative Office, Constituent Services Office, Scheduling Office, Appointments Office, Policy Office, Administration Office, Office ofthe First Lady, and Governor's Mansion. B. Unless othensise specified, all items shall encompass the period of time beginning January 17, 2011 to the present C. Documents responsive to any items shall be produced together, in electronic or paper fle folders or with other enclosures that separate the files by item number. Ifa document is responsive to ‘more than one item, it shall be produced in response tothe item to which iis primarily esponsive, Dosuments and Things Requested 1. A.complete copy of your personnel file(s) with the State of Alabama or the Office cf the Governor, 2, Any and all documents, eletronic deta, and information evidencing or relating to your daily and weekly schedule from January 17, 2011 to March 30, 206 3. Your federal and state income tax returns, including all schedules, attachments, and W- 2s, for 2011 to the present, 4. Any and all documents, eleetronie data, and information evidencing or relating to any and all work, services, or goods you performed for or provided tothe State of Alabama, the Office of ‘the Governor, the Alabama Council for Excellent Goverment, Bentley for Governor, Inc. or Governor Robert Bentley in his personal capacity. 5. Any and all documents, electronic data, and information evidencing or relating to any and ll compensation, reimbursements, expenses, and payments of any kind made to you by the State ‘of Alabama, the Office of the Governor, the Alabama Council fr Excellent Government, RCM ‘Communications, Ine, JRM Enterprises, ne, or Bentley for Governor, Inc 6. Any and all documents, electron data, and information evideneing or relating to any and all compensation, reimbursements, expenses, and payments of any kind made by you to the State Page 2 of 5 of Alabama, the Office ofthe Governor, the Alabama Council for Excellent Government, RCM ‘Communications, In., JRM Enterprises, Inc. or Bentley For Governor, Inc 7. Any-and all ocuments, electronic data, and information evidencing or relating to any loans, gifs, payments, or ther transfers of money or things of value to you from or on behalf 9f ‘Governor Robert Bentley in his personal capacity 8, _All statements for any checking, savings, or investment account into which, or Yom Which, any ofthe compensation, reimbursements, expenses, loans, gifts, payments, oF other transfers of money or things of value referred to in Requests 5 through 7 were deposited or withdrawn, 9, Any and all documents, electronic data, and information evidencing or relating to any requests for reimbursement from State funds, including all supporting documentation, submited by you or on your behalf from January 1, 2013 to the present 10. Any and all documents, elettoni data, and information evidencing o relating to your job tiles, duties, or performance with or forthe Office ofthe Governor, the State of Alabama, Bentley or Governor, Ine, othe 2014 gubernatorial campaign of Governor Robert Bentley. 11. Any and all documents, electronic data, and information evidencing or relating to any flings you have submitted o, or training you have received from, the Alabama Ethies Commission. 12, Any and all documents things, or eletronic data that you removed from State roperty 13, Any and all ocuments, electronic dat, and i March 30, 2016 evidencing o relating to State business. formation that you have receivec since 14, Any and all ocuments electronic data, and information evidencing or relating to any ‘meetings at which both Governor Robert Bentley and Spencer Collier were present from January L 2014 to the present. 15. Any and all Jocuments eletronic data, and information evidencing o relating o any nondisclosure or confidentiality agreements signed by you or proffered to you by oron behalf of ‘Governor Robert Bentley, i is personal capacity, or the Office of the Governor. 16. A.complete lst of any and all cellar phones of mobile devices owned or usedby you, including for each phone or device the telephone number, account number, the name of the carrier, and the dates of use r service. 17, All ills and usage histories for any cellular phone or mobile device listed in response to the previous Request 18, A-complete lst oF any and all email accounts and social media accounts owned or used by you. 19, Any and all documents, electronic data, and information evidencing or relatingto any communications, including but expresely not limited to leters, notes, emails, text messages, and voive messages, between you and any of the following persons, including eny atomey or other person acting for or on behalf of ether you or them: 8. the Office ofthe Governor; b. Governor Robert Bentley in is personal capacity; Page 3 of 5 Dianne Bentley: any other member ofthe Bentley’ faily Spencer Collier Stan Stabler Ray Lewis; ‘any director, office, employee, agent, or representative of Alabama, Ceuncil for Excellent Government ; any director, officer, employee, agent, oF representative of Bentley for Governor, In any director, officer, employee, agent, or representative of RCM (Cemmunications, Ine 20. Any and all documents, electronic dat, and information evidencing or relating to ary ‘communications, including but expressly not limited to letter, notes, emails, text messages, and voce messages, sent to oF rece ved by you concerning: b the Office ofthe Governor; Governor Robert Bentley in is personal capacity; Dianne Beatles any other member ofthe Bentley familys Spencer Coli; Stan Stable Rey Lewis Bentley for Governor, Ines [Akibama Council for Excellent Governments ‘Alsbama Law Enforcement Agency or any ofits subordinate agencies, departments, or divisions; a State airerat REM Communications, ne: JRM Enterprises, nes ‘Matt Hart Mike Duly, of anyother person iavolve in the ‘estigation, indictment, prosecution, o ral of former Alabama Speaker ‘ofthe House Mike Hubbard; Page 40f5 0. the investigation, indiciment, proseeution, or trial of former Alabama ‘Speaker ofthe House Mike Hubbard 21. Any and all documents, electronic data, and information evidencing or relating to any of the following: & The Offee ofthe Governer; b, Governar Robert Bently in is personal capacity; Dianne Sentley; 4. any other member ofthe Bente family; ©. Alabama Council for Excellent Government or any ofits current or former directors or officers; f, Alabama Law Enforcement Agency or any of its subordinate agencies, departments, or divisions including any current of former officers or employees of any ofthe foregoing: & State ai h. RCM Communications nes i, IRM Breerprises, Ines |. Mat Har, Mike Duffy, or any other person involved in the investigation, indictment, prosecution, or trial of former Alabama Speaker of the House Mike Hubbard; k. the investigation, indictment, prosecution, o ral of former Alabama Speaker ofthe House Mike Hubbard 22, Any and all aucio or video recordings of any part of any telephone or other conversations between you and Governor Robert Bentley 23, _ Any and all documents, electronic data, and information evidencing or relating to Statements of Economic Interests filed by you with the Alabama Ethies Commission 24, Any and all documents, electronic data, information, or other things that you believe are relevant, in any way, to the proposed Atielea of Impeachment Against Goveener Bentley, a eopy of ‘hich is enclosed as Attachment I, or the investigation pertaining thereto. Page Sof S R367 176360-2 By Representatives Henry, Whorton (I), Sessions, Ball, Patterson, Hanes, Whorton (R), Holmes (i), Standridge, Moore (B), Crawford, Parley, Willians (JW), Ainsworth, Ford, Todd, Wilcox, Butler, Nordgren, Williams (P), Morrow, Ingram and Mooney RED: Judiciary First Read: 28-APR-16 Page 0 ATTACHMENT | a0 nn 2 13 4 16 uw 18 1 20 a 22 23 24 25 26 4/27/2016: 9BT/th LRS2016-1344R1 ARTICLES OF IMPEACHMENT AGAINST GOVERNOR BENTLEY. WHEREAS, in 2010, Governor Bentley was elected the 53rd Governor of the State of Alabama and was reelected to a second term in 2014; and WHEREAS, Section 173 of the Constitution of Alabana of 1901 provides that the Governor and other constitutional officers of thie state may be impeached upon the adoption of articles of impeachment by this body and upon trial by the Senate, acting as a court of impeachment; and WHEREAS, two formal complaints have been filed with the Alabama Ethics Conmission to determine whether Governor Bentley vielated state ethics laws by misusing state property; and WHEREAS, in recognition of the gravity of the adoption of these articles of impeachment and upon findings that Governor Bentley has violated the public trust, this bedy concludes Governor Bentley should Le impeached fox causes now therefore, Page ATTACHMENT 1 10 an 12 13 uu BE IT RESOLVED BY THE HOUSE OF REPRESENTATIVES OF ‘THE LEGISLATURE OF ALABAMA, That Governor Bentley is impeached for cause and that the following articles of inpeachnent, based upon the findings in this resolution, be transmitted to the Senate for trial as provided in Section 173 of the Constitution of Alabama of 1901: ARTICLE Willful Neglect of Duty. Credible evidence exists to create probable cause to believe that, in his conduct while Governor of the State of Alabama, he willfully neglected his duty as Governor by failing to faithfully execute the laws of this state and by refusing to perform his constitutional and statutory duties. ARTICLE IT. Corruption in office. Credible evidence exists to create probable cause to believe that, in his conduct while Governor of the State of Alabama, he unlawfully misused state property, misappropriated state reso es, and consistently acted in violation of law Promote his own personal agenda. Page 2 ATTACHMENT | BEFORE THE JUDICIARY COMMITTEE (OF THE ALABAMA HOUSE OF REPRESENTATIVES, TO: Alabama Counc! for Excellent Government SUBPOENA clo Richard J. R Raleigh, Jr, Esq. Wier & Ler,P.A. 100 Washington Street Northeast ‘Huntsville, Alabama 38801 PURSUANT TO THE COMMITTEE RULES OF THE HOUSE JUDICIARY COMMITTEE FOR THE IMPEACHMENT OF GOVERNOR ROBERT BENTLEY, THE JUDICIARY COMMITTEE OF THE ALABAMA HOUSE OF REPRESENTATIVES (*THE COMMITTEE") HEREBY COMMANDS YOU: [Do appear before the Committee and be questioned at the place, date and time specified below: Place: _ Date Time: To produce the materials, identified in the attached Exhibit A, to the Committee atthe place,

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