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21. <br />La. R.S. 42:1155A <br />provides the following with respect to ill-gotten gains: <br />If an investigation conducted pursuant to this Part reveals that any public servant <br />or other person has violated any law within the jurisdiction of the Board of Ethics <br />to his economic advantage, and after an adjudicatory hearing on the matter, the <br />Ethics Adjudicatory Board may order the payment of penalties. Recovery may <br />include, in addition to an amount equal to such economic advantage, penalties not <br />to exceed one half of the amount of the economic advantage. <br />VI.PRAYER FOR RELIEF <br />22. <br />Based on the foregoing factsalleged herein,Ricky L. Cleveland, while serving as amember <br />of the Commission,violated La. R.S. 42:1111C(2)(d) by virtue of receivinga thing of economic <br />valuetotaling $4,675,681.26for services rendered in 2022, 2023, 2024, and 2025to RLC <br />Trucking,which was at a time when RLC Trucking conducted operations andactivities that are <br />regulated by the Commission. <br />23. <br />Based on the foregoing facts alleged herein, RLCTruckingviolated La. R.S. 42:1117 by <br />virtue ofpayinga thing of economic value to Prodigy and Ricky L. Cleveland,to which Ricky L. <br />Cleveland and Prodigy are prohibited from receiving by La. R.S. 42:1111C(2)(d). <br />WHEREFORE <br />,the Louisiana Board of Ethics respectfully prays that: <br />(a)The Ethics Adjudicatory Board conductsa hearing on the foregoing <br />charges; <br />(b)The Ethics Adjudicatory Board determinesthat Ricky L. Clevelandviolated <br />La. R.S. 42:1111C(2)(d)with respect to the foregoing alleged facts; <br />(c)The Ethics Adjudicatory Board determinesthat RLC Trucking, LLC, <br />violated La. R.S. 42:1117with respect to the foregoing alleged facts; <br />(d)The Ethics Adjudicatory Board assess appropriate penalties in accordance <br />withLa. R.S. 42:1153, 1154,and 1155; and, <br />Page 7of 8(Agency Tracking No. 2025-495) <br /> <br />