Months after an investigation by the Georgia Bureau of Investigation into Bulloch County’s Public Works department over Hurricane Helene-related invoices was opened and then later closed, the complete case file has been released under the Georgia Open Records Act.
The file, which includes copies of the invoices and a number of interviews with public officials and business owners, indicates that GBI agents determined there were discrepancies with the invoices submitted by Sand Creek Land Construction which is owned by Clay Conner, brother of Commissioner Toby Conner. While some of the discrepancies were attributed to what Conner said was an ‘industry standard’ for 8-hour minimums on truck rentals and hauling that were not reflected as line items on invoices, other discrepancies were eventually determined to be ‘simple miscalculations’ on the invoices. According to the case file, Conner was paid upwards of half a million dollars in the wake of the 2024 storm recovery.
In July 2025, Clay Conner and his attorney met with the GBI, after all parties signed a proffer agreeing that anything Conner offered in the interview could not be used against him in a criminal or civil proceeding by the GBI or Prosecuting Attorney’s Council of Georgia (PAC). The recorded interview reflects a repeated assertion by Conner that he did nothing wrong, that the investigation was politically motivated, and a clear acknowledgement of the miscalculations. It was noted in another recorded interview with another party that Clay Conner had since taken efforts to upgrade “how they do things” and have “since put things in place” in the business practices.
Given the volume of information in the case file and the number of recorded interviews, the information will be released in a series of articles. The documents will be released in the order in which the various interviews were conducted over the course of the investigation. A number of interviews include no data on their date of occurrence and will be published in the order they appeared in the file. A follow-up has been submitted to the GBI, but has not been provided. If/when additional details of interview dates are submitted, they will be included in the forthcoming parts.
A complete list of documents and interviews conducted, all of which will eventually be published, can be viewed in the timeline below.
CASE TIMELINE
Friday, February 28, 2025 – Commissioner Ray Davis contacts District Attorney Robert Busbee.
Friday, February 28, 2025 – District Attorney Robert Busbee requests assistance from the GBI after receiving information from a concerned resident. The letter says Busbee was notified of concerns regarding 1) bidding, and 2) an unnamed county commissioner, and) a county employee named “Dink Butler.”
Tuesday, March 4, 2025 – Bulloch County Commissioners hold their regular meeting. The issue of invoices and Sand Creek Land Construction are discussed during the public comment portion of the meeting. Meeting can be viewed here.
Wednesday, March 5, 2025 – 8:45 a.m – GBI Interviews Commissioner Ray Davis. Listen to his interview here.
Wednesday, March 5, 2025 – 1:31 p.m. – GBI Interviews Clay & Megen Conner
Thursday, March 6, 2025 – 8:53 a.m. – GBI Interviews Public Works Director Dink Butler & Asst. Public Works Director Robert Seamans.
Chairman David Bennett [Interview date not listed on audio recording or in case file. Interview time is 11:15 a.m. (based on interview end time) published in order it appeared in case file]
Commissioner Nick Newkirk [Interview date not listed on audio recording or in case file. Time ~8:25 a.m. (based on interview end time) published in order it appeared in case file]
Commissioner Anthony Simmons [Interview date not listed on audio recording or in case file. Time ~12:00 p.m. (based on interview end time) published in order it appeared in case file]
GBI Interviews Commissioner Ray Mosley [Interview date not listed on audio recording or in case file. Time 9:53 p.m. (based on interview end time) – published in order it appeared in case file]
GBI Interviews Commissioner Timmy Rushing – [Interview date not listed on audio recording or in case file. Time 10:14 a.m. – published in order it appeared in case file]
Monday, March 10, 2025 – GriceConnect breaks the news that there is a GBI investigation. TheGeorgiaVirtue also notes an active GBI investigation in an article about the ethical concerns about Commissioner Toby Conner voting on the approval of funding for work completed by his brother.
GBI Interviews Commissioner Toby Conner [date not listed but comments from agent in the audio indicate it occurred after the month of March]. Time 10:06 a.m (based on interview end time). – published in order it appeared in case file]
No one else was interviewed by the GBI, but in July, the GBI does interview Clay Conner a second time.
April 11, 2025 – The District Attorney’s Office notifies PAC that the GBI investigation, which is still ongoing, will create a conflict for his office. The DA’s office did not formally ‘conflict out’ because the office did not receive the case file since Busbee notified PAC while the investigation was ongoing. The GBI does not forward its eventual findings to the Ogeechee Circuit DA’s office and instead consults with PAC.
Monday, July 14, 2025 – Clay Conner and his attorney submit a proffer to the GBI and Prosecuting Attorney’s Council of Georgia which prohibits the use of the content of Conner’s interview in any criminal or civil proceeding against him so long as the content is truthful and complete. The fact that the proffer has been made is also prohibited from being used in any criminal or civil proceeding against Clay Conner. Read the proffer. A copy of the document signed by the prosecutor in the case is available here.
Tuesday, August 19, 2025 – Conner and his attorney appear at the Bulloch County Commission meeting. Conner’s attorney, Jim Durham, tells the commissioners his client has been treated unfairly and that Conner voluntarily sat down with the GBI with all of the information about his business. Read the story.
Wednesday, Aug 20, 2025 – The Executive Director of the Prosecuting Attorney’s Council signs an order appointing a District Attorney Pro Tem to handle the case. (Note: This is when the order was signed, but PAC was handling the case prior to this date because the PAC prosecutor is referenced in the case file prior to this date and Busbee notified PAC of the potential conflict on April 11, 2025.)
Wednesday, Aug 20, 2025 – The Prosecuting Attorney’s Council pens a letter to the GBI stating, “Based on your findings and our analysis of the case, there is no readily provable criminal intent, and the case is declined.” Read the story.
Thursday, Aug 21, 2025 – TheGeorgiaVirtue filed an Open Records Request for the complete case file. The GBI replies the same day to report that the case is still open and pending and, therefore, the records are not available. View the email response from the GBI indicating that the file was not subject to release.
Tuesday, Aug 26, 2025 – TheGeorgiaVirtue again files an Open Records Request for the complete case file. [Documented in response from GBI here]
Tuesday, Sept. 2, 2025 – The GBI replies with the cost estimate for the case file and states the file will be ready on or before November 19, 2026 at 8:30 a.m. (Not a typo on the part of TGV, the GBI invoice lists the completion date as more than one year from the date of request. View the email response from the GBI.)
Friday, Oct. 3, 2025 – The GBI file is provided to TheGeorgiaVirtue. It notes that some personally identifiable information was redacted during preparation of the file, as is permitted under the Georgia Open Records Act.[View the email dated October 3 indicating that the case file is available for download]
Sand Creek LLC Invoice – 2183
Sand Creek LLC Invoice – 2187
Sand Creek LLC Invoice – 2188
Sand Creek LLC Invoice – 2191
Sand Creek LLC Invoice – 2192
Sand Creek LLC Invoice – 2198
Sand Creek LLC Invoice – 2199
Sand Creek LLC Invoice – 2205
Sand Creek LLC Invoice – 2206
Sand Creek LLC Invoice – 2207
Sand Creek LLC Invoice – 2208
Sand Creek LLC Invoice – 2215
Sand Creek LLC Invoice – 2216
Sand Creek LLC Invoice – 2222
Sand Creek LLC Invoice – 2223
Sand Creek LLC Invoice – 2253
Sand Creek LLC Invoice – 2258
Sand Creek LLC Invoice – 2260
Sand Creek LLC Invoice – 2263
Sand Creek LLC Invoice – 2265
Sand Creek LLC Invoice – 2270
Sand Creek LLC Invoice – 2283
Sand Creek LLC Invoice – 2289
Sand Creek LLC Invoice – 2292
Sand Creek LLC Invoice – 2300
Sand Creek LLC Invoice – 2308
Sand Creek LLC Invoice – 2314
Sand Creek LLC Invoice – 2316
Sand Creek LLC Invoice – 2318
Sand Creek LLC Invoice – 2322
Sand Creek LLC Invoice – 2325
Sand Creek LLC Invoice – 2334
Sand Creek LLC Invoice – 2335
Sand Creek LLC Invoice – 2335 Duplicate
Sand Creek LLC Invoices List
Part 1: The GBI Interviews Commissioner Ray Davis
This interview was conducted on Wednesday, March 5, 2025. The full audio clip is below the text. The time stamps below detail a rough outline of conversation points from the discussion between GBI Agent Justin Jones and Commissioner Ray Davis.
1:45 – The first question after his DOB, Agent Jones asks, “We’re here about some discrepancies you noticed. When did you notice them at first?”
3:20 – Davis references an invoice for 219 hours from Sand Creek Construction, which prompted him to contact Public Works Director Dink Butler because he had concerns about the number of trucks and total hours. He stated he didn’t think Sand Creek had enough trucks to be running the number of hours in a week that they were.
6:40 – Davis presents a text to Jones regarding a text from Clay Conner. He then explains that the public works director ‘threw him under the bus’ to Sand Creek Construction.
8:00 – Davis mentions that Clay Conner’s brother is a county commissioner and has voted on the issue, but has been recusing himself lately. “I don’t know if anything’s gone on criminal here,” Davis says.
10:15 – Davis tells Agent Jones about Butler’s comments at a commission meeting and outlines the tracking system for the trucks for hauling. He says he told Butler that the process wasn’t good enough for county commissioners to pay.
11:38 – Davis asks how he can be sure the hours haven’t been padded.
12:20 – Davis mentions Commissioner Toby Conner’s comments about Sand Creek Construction at the meeting. “His brother gave a resounding ‘kiss my ass,’ ‘my brother works so hard,’”
“When people get up there like that, and what Dink’s done, it makes ‘em look guilty. Now whether there’s something there or not, I don’t know. Whether this is illegal, I don’t…subbing out…I don’t know that it’s illegal, but I don’t know what the hell’s going on.”
13:00 – Agent Jones asks Davis if someone else noticed the discrepancies and brought them to his attention, independent of him.
14:15 – Davis says he saw discrepancies and he asked public works and now it’s been thrown back on him.
15:07 – Agent Jones asked if any other commissioners are aware of the discrepancies noticed by Davis. The question is asked again at 19:45. Davis replies that Clay Conner is in business with Timmy Rushing, who is also a sitting commissioner.
27:25 – Davis tells Agent Jones he doesn’t want ‘this’ to come back on him. Jones explains how the investigation process works and that he can ‘shield him’ to the best of his ability, but that it will be on record and the accusation has to come from somewhere.
29:25 – Davis says he’d rather pull back and not do this, to which Jones replies that he would have to discuss with his superiors and the district attorney, since that’s who made the request. Jones then states it would be best to make sure there is nothing illegal occurring.
32:45 – “If y’all investigate public works, whether you find something or not, and it comes back to me, that has destroyed my relationship as a county commissioner with every other employee that this county has.”
33:05 – Agent Jones replies that if an investigation is conducted and they determine there’s no illegal activity, that it was just a misunderstanding, “at least it’s confirmed that it’s just a misunderstanding and it’s on the up and up.” Jones said
36:00 – Jones also tells him that doing the right thing for the right reasons can put a target on his back. Davis replies again that he’s not mistaken about anything, he doesn’t know if there’s anything criminal.
He said he contacted the district attorney because after he contacted Public Works Dink Butler, he got thrown under the bus. “Who am I supposed to talk to?”
Jones reiterated to Davis that he ‘did the right thing by identifying the issue and telling someone about it and he did the right thing by initiating a criminal investigation. “We have cases where we investigate and it’s determined that there’s no criminal activity.
38:10 – “What if this is nothing illegal but it’s unethical?” Davis asks. “There ain’t but one person who created all this and that’s Dink Butler.”
Agent Jones answers that the GBI doesn’t investigate ethical issues but that Davis is doing nothing wrong by seeking answers and confirming everything is on the up and up. He said he would speak with his superiors about how to move forward.
43:50 – “Because of what I see and what I’m doing for my community, this has turned into a damn nightmare. There ain’t but one person responsible for this and that’s Dink Butler with Public Works,” Davis says.
The conversation then turns back to the cost of the hauling
45:30 – “Where is the other $15? [In reference to the $105/load charge by one company and the $90 charge for another trucker]. They might be paying him cash money. I don’t know if Dink ain’t skimming something off it. I know there’s $15 difference.”
46:30 – “In my opinion, I don’t see nothing criminal. I see something that’s unethical,” Davis says. “And there’s a big difference.”
Davis then says he’s questioning whether or not he should have made the call to the district attorney at all, but then follows with that he knows Busbee had a ‘duty and responsibility’ to make a call to the GBI. He said the implications of this will impact his wife, too.
52:45 – Agent Jones again asks Davis if he is the only person that knows about the discrepancies, other than other commissioners.
55:30 – Davis shares that he was talking to Lawton Sack and Cassandra Mikell the night prior and he [Davis] told Sack “I bet I said to him 15x, I need something that’s illegal.” and he said ‘so and so and so and so’ and I said “That’s unethical, but is it illegal? So he don’t have nothin’ but he told me last night that he’s going to do an Open Records Request on Public Works about these trucks because I would not tell him who the other trucker was that was only getting paid $90 [a load].”
56:45 – Davis says the Conner family won’t even speak to him because they think he instigated this.
Thompson Consulting Invoice
SDR Invoice
Sand Creek Invoice
Derriso Invoice
Anthony Simmons newspaper excerpt
Listen to the full audio file below.
