Warrant in Evergreen Nursery theft

ARRESTWARRANT~rrL."W#q

For Court Use Only

STATE OF CONl\IEC,:TI~:~~i SUPERIOR

.JD-CR路64b Rev. 1-11 e.G.S 搂 54路2a Pro Bk. Sec. 36-1, 36-2. 36-3

www.jud.ct.gav

Police Case number

Agency name

10-16430

SOUTHINGTON POLICE DEPARTMENT

Name (Last, First, Middle Initial)

Residence (Town) of accused

MILEWSKI, Doreen

BRISTOL

17

Application For Arrest Warrant To: A Judge of the Superior Court The undersigned hereby applies for a warrant for the arrest of the above-named accused on the basis of the facts set forth in the: [gJ Affidavit Below.

Affidavit(s) Attached.

D

Date

Signed (Prosecuting a

Typelprint name of prosecuting authority

'3 ~

-

Affidavit The undersigned affiant, being duly sworn, deposes and says:

1... That the Affiant, Detective Mark Beal, being duly sworn, does depose and state that I am a member of the Southington Police Department and have been a police officer for approximately twenty (20) years prior to this date. Affiant Beal has been promoted to the rank of Detective and has worked as a Detective for about the past three years. At all times mentioned herein, was acting as a member of said department. That Affiant Beal has attended numerous schools, seminars, training classes and in-service training over the years dealing with and specializing in criminal investigations and related activities. That Affiant Beal has participated in numerous investigations involving Criminal Activities and related events which have led to the arrests and convictions of those involved as well as the seizures of evidence, contraband, stolen properties and other related items. The following facts and circumstances are stated from personal knowledge and observations, as well as information received from other police officers acting in their official capacity, and from official police reports and statements made by prudent and credible witnesses. That Affiant Beal feels that the information contained herein provides probable cause for the issuance of said warrant.

2. On October 7, 2010 the Southington Police Department received a complaint from Fred Kuhr, ("Mr. Kuhr") and Elke Kuhr ("Mrs. Kuhr") the owners of Evergreen Nursery at 567 Woodruff St. Southington, CT. that he recently hired a forensic accountant, Forensic Accounting Services LLC, to review his financial records from 2007 through to 2009 due to suspicion of employees possibly forging invoice documents for the purpose of obtaining cash funds from cash paying clients.

3. On October 7, 2010 Mr. Kuhr provided two copies of the Forensic Accounting Analysis along with an electronic data CD containing records and exhibits provided by Forensic Accounting Services LLC. According to the findings, it was concluded that Evergreen Nursery suffered a loss of approximately $34,021.00 dollars through a skimming and lapping scheme. The findings revealed that cash paying customers accounts were altered in the company's electronic financial accounting records.

(This is page 1 af a 18 page Affidavit.)

Date

Jurat

Finding The foregoing Application for an arrest warrant, and affidavit(s) attached to said Application, having been submitted to and considered by the undersigned, the undersigned finds from said affidavit(s) that there is probable cause to believe that an offense has been committed and that the accused committed it and, therefore, that probable cause exists for the issuance of a warrant for the arrest of the above-named accused.

Date and Signature

On (pate) (

\\

I( i

Signe(:udgeIJ~dge Trial Referee)

f)y--

ARREST WARRANT APPUCJ\,TION J D-C R-64a Rev. 1-11 C.G.S. ยง 54-2a Pro Bk. Sec. 36-1, 36-2, 36-3

ST/\TE OF CONNECTICUT SUPERIOR COURT www.jud.ct.gov

Name (Last, First, Middle Initial)

Residence (Town) of accused

Court to be held at (Town)

Geographical

MILEWSKI, Doreen

BRISTOL

BRISTOL

Area number

17

Affidavit - Continued 4. Forensic Accounting Services LLC was engaged to assist in this investigation by analyzing the financial transactions and activity of Evergreen Nursery, INC (Evergreen) with the specific goal of identifying any and all unauthorized activity. As part of their services they were engaged to assist Evergreen personnel in conducting their internal investigation into identifying potential unauthorized activity purportedly committed by Evergreen's former Administrative Assistant, Doreen Milewski and her assistant Mary Giannotti.

5. On or about October 18, 1983 Kuhr hired Milewski in the capacity of administrative assistant, but over time Milewski's role envolved into working as the equivalent of office manager for Evergreen. Throughout her employment Milewski was responsible for certain financial aspects of Evergreen, with the assistancae of bookkeepers and or assistants. Many different bookkeepers worked at Evergreen throughout the period, including Mary Giannotti during the approximate period 2007 though 2009. Milewski's financial duties were invoicing customers, collecting payments from customers, calling customers for collections, completing deposits in Kuhr's absence or unavailability, and completing the deposit summary sheets.

6. In 2007 Evergreen employed Giannotti in the capacity of bookkeeper and/or controller for a period of about three years. Giannotti ended her employment with Evergreen on or about October 2009. Giannotti was responsible for accounts receivable, accounts payable, and the QuickBooks electonic finacial data entry records for Evergreen.

7. Mrs Kuhr explained their job summary and payment process. She stated a new customer project would be initiated with a proposal for work to be performed by Evergreen for a customer. Once the proposal was accepted, Evergreen workers would perform the services and complete a "Job Sheet" (a1k1a "work order") describing the services performed and other details. The workers would then return the completed job sheets to the office, delivered primarily to Milewski. Milewski was responsible for entering the information from the Job Sheet in the form of an invoice to the customer through QuickBooks, the accounting system utilized by Evergreen. Milewski would then send the invoice out to the customer for payment.

8. Mrs. Kuhr stated customer payments were received by Evergreen in four different ways. a. The first collection method was that the customer mailed their payment to Evergreen. Mr. Kuhr primarily opened the mail and prepared the deposit. In the instances when Mr. Kuhr was busy or unavailable, Milewski opened the mail and prepared the deposit. Milewski recorded the payments within QuickBooks. Giannotti could also process the deposits when Mr. Kuhr was unavailable. b. The second collection method was for customers to bring their payment (cash or checks) to the garden center at Evergreen. The payments would be placed into an envelope and forwarded to the office. Milewski would receive the payments for recording within QuickBooks.

(This is page 2 of a 18 page Affidavit.)

Date

Signed (Affiant)

Subscribed and sworn to before me on (Date)

Jurat

I-dO-II

Signed (

ARREST WARRANT APPLICATION JD-CR-64a Rev, 1-11 C.G.S. ยง 54-2a Pro 81<. Sec, 36-1, 36-2, 36-3

STATE OF CONNECTICUT SUPERIOR COURT www.jud.ct.gov

Name (Last, First, Middle Initial)

Residence (Town) of accused

Court to be held at (Town)

MILEWSKI, Doreen

BRISTOL

BRISTOL

Geographical Area number

17

Affidavit - Continued

c. The third collection method was for Evergreen workers to collect customer payments (cash or checks) at the time of the work being performed. The workers brought the payments back to the office, and provided the payments to Milewski. d. The fourth collection method was for customers to pay Evergreen by credit card. Customers made credit card payments at the garden center, or they called the office and provided their credit card information to Milewski.

9.

Mrs. Kuhr stated Giannotti and Milewski had access to Evergreen's QuickBooks.

10. On or around August 2008 Mr. Kuhr required surgery, and around the same time Elke B. Kuhr ("Mrs. Kuhr") started coming to work at Evergreen and looking over the financial records. Mrs. Kuhr was familiar with the business and operations having worked at Evergreen from inception through approximately 2003 when Mrs. Kuhr fully retired from Evergreen.

11. On or around August 7, 2009 Milewski was terminated (laid off) from Evergreen. Mrs. Kuhr continued her review of the financial records of Evergreen. Mrs. Kuhr stated the financial and customer files were always a mess, and that Milewski was the only person who could find anything in the files including the phone numbers of Evergreen customers.

12. Mrs. Kuhr stated on or around the Fall of2009 after Milewski was terminated, Giannotti came to Mrs. Kuhr and told her she was afraid that if anyone researched prior deposits and determined someone was stealing from Evergreen, it would look as if Giannotti was stealing when in fact she had stolen nothing from Evergreen. Mrs. Kuhr stated Giannotti told her that often Milewski would come to Giannotti and ask her to re-write deposit slips, and that Milewski would take the deposits to the bank. Mrs. Kuhr stated Giannotti was concerned that the deposit slips would be in Giannotti's handwriting, when in fact they were re-written at the request of Milewski who made the actual deposits, and who caused the differences in the deposit details. Mrs. Kuhr stated Giannotti showed her (Mrs. Kuhr) what was happening with the deposits and the deposit differences, and provided Mrs. Kuhr with examples of the deposits. Mrs. Kuhr stated Giannotti assisted her (Mrs. Kuhr) in identifYing the cash paying customers and the deposits in question. Mrs. Kuhr stated after she worked with Giannotti, she (Mrs. Kuhr) went to the bank to obtain images of all of the deposits made by Evergreen for the period 2007 through 2009, and reviewed every deposit provided to identifY deposits with differences.

(This is page 3 of a 18 page Affidavit.)

Date

Signed (Affiant)

(i

ARREST WARRANT APPUCA TiON JD-CR-64a Rev. 1-11 C.G.S. ยง 54-2a Pro Bk. Sec. 36-1, 36-2, 36-3

STATE OF CONNECTiCUT SUPERIOR COURT www.jud.ct.gov

Name (Last, First, Middle Initial)

Residence (Town) of accused

Court to be held at (Town)

MILEWSKI, Doreen

BRISTOL

BRISTOL

Geographical Area number

17

Affidavit - Continued

13. Mrs. Kuhr stated during her review that she determined the last two digits of customer phone numbers were switched or reversed, preventing anyone from contacting the effected customers using the recorded phone numbers in the files.

14. Mrs. Kuhr stated incidents of theft had been occurring within the office, but that they were never able to determine who was responsible. Mrs. Kuhr stated in one incident during the summer 2009 Giannotti had money personally taken from her at Evergreen. Mrs. Kuhr stated only Giannotti and Milewski were present during the time of Giannotti's loss. Mrs. Kuhr stated in a second incident Mrs. Kuhr placed $80 into the safe at Evergreen, at the time when only she and Milewski were present. Mrs. Kuhr stated the next morning the $80 was missing from the safe.

15. Mrs. Kuhr stated on or around June 2009 Milewski purchased New York Giants tickets from a customer (John Fontana) for approximately $600. Mrs. Kuhr stated according to the customer, Milewski made a partial payment of $250 for the tickets. The customer received a letter from Milewski, causing the customer to drive to Evergreen to meet with Mr. Kuhr. The customer told Mr. Kuhr that Milewski offered to credit off some outstanding unpaid invoices in the customer in lieu of repaying the balance of the football tickets. The customer told Mr. Kuhr he did not accept her offer, and paid Mr. Kuhr for his outstanding unpaid balances with Evergreen.

Copies of the letter and supporting information were provided by Mrs. Kuhr. This is described as Exhibit A, 5 paper documents which include a letter from Fontana and invoices from Evergreen.

16. Mrs. Kuhr stated during her review she compared deposits recorded within Evergreen's QuickBooks to actual deposits. If there were any differences identified within a deposit, the deposit was set aside and further researched. Mrs. Kuhr stated she identified four customers that historically paid Evergreen in cash, and that the activity and deposit records for these four customers did not match with the Job Sheets prepared when work was actually performed for these four customers. Mrs. Kuhr identified the following customers: a. Raju Avancha 345 Mt. Vernon Road Plantsville, CT 06479 b. Murthy Kandarpa 215 Mount Pond Road Southington, CT 06489 c. Carol Ann Giammatteo 66 Sabina Drive Southington, CT 06489

(This is page 4 of a 18 page Affidavit.)

Date

Jurat

Signed (Affiant)

Signed~ "

ARREST WARRANT APPUCATION JD-CR-64a Rev. 1-11 C.G.S ยง 54-2a Pr. Bk. Sec. 36-1, 36-2, 36-3

STATE OF CONNECTICUT SUPERIOR COURT www.jud.cLgov

Name (Last, First, Middle Initial)

Residence (Town) of accused

Court to be held at (Town)

MILEWSKI, Doreen

BRISTOL

BRISTOL

Geographical Area number

17

Affidavit - Continued d. Phil Pomposi

1215 Pleasant Street Southington, CT 06489 17. Mrs. Kuhr stated she reviewed all of the Job Sheets for these customers, quantified the work that was performed for each Job Sheet, and compared the amounts to actual deposits received from these customers. Mrs. Kuhr stated she then sent letters to each of the identified customers on February 22, 2010 (Avancha), March 16, 2010 (Giammatteo) and March 22,2010 (Kandarpa) showing the work performed and the payments received by Evergreen. Mrs. Kuhr provided copies of the letters which were labeled Exhibit B in the case file.

18. Mrs. Kuhr stated she never received responses from Raju Avancha or Murty Kandarpa. Mrs. Kuhr stated Carol Ann Giammatteo came to Evergreen upset in response to the letter, and stated she had paid all of her invoices in cash.

19. Mrs. Kuhr stated she filed notice of an insurance claim with Farm Family Insurance Company on March 22, 2010. A copy of the notice of a loss was provided and was labeled Exhibit C in the case file.

20. On May 6, 2010 Stephen Pedneault, CPA, CFE, CFF, FCPA, of Forensic Accounting Services LLC met with Mr. and Mrs. Kuhr at Evergreen in Southington, Connecticut. Mrs. Kuhr provided him an explanation of her findings as well as copies of various information she identified to date. Mrs. Kuhr provided copies of deposits she had identified with differences between the listed deposit items per the Daily Receipt Sheets and the actual bank deposit slips.

21. After Pedneault met with Mrs. Kuhr and reviewed the work she had performed to date, he provided Mrs. Kuhr with additional procedures she should perform to determine the full extent of the unauthorized activity.

22. Pedneault also inquired of Mrs. Kuhr if the original hard drive maintained within the computer used by Milewski and Giannotti containing Evergreen's QuickBooks files had been preserved. Mrs. Kuhr indicated it had not been preserved. Pedneault instructed Mrs. Kuhr to purchase an external hard drive and to preserve the hard drive files including Evergreen's QuickBooks files onto the new external hard drive.

23. On August 6, 2010 Pedneault returned to Evergreen and met with Mrs. Kuhr. Mrs. Kuhr provided him further information for the identified customers as well as access to Evergreen's QuickBooks records.

24. Mrs. Kuhr provided Pedneault one Seagate external hard drive and indicated the files maintained on the computer's hard drive including Evergreen's QuickBooks files had been preserved on the new external hard drive.

Pedneault secured the drive as evidence, logged and labeled the drive, and later that day Pedneault secured the drive within his firm's evidence room maintaining a chain of custody.

(This is page 5 of a 18 page Affidavit.)

Date

Signed (Affiant)

Signed (

Jurat

6CLlยฃ Reviewed (Judge/Judge

ARREST WARRANT APPLICATiON JD-CR-64a Rev. 1-1'1 C.G.S. ยง 54-2a Pro Bk. Sec. 36-1, 36-2, 36-3

STATE OF CONNECTiCUT SUPERIOR COURT www.jud.ct.gov

Name (Last, First, Middle Initial)

Residence (Town) of accused

Court to be held at (Town)

MILEWSKI, Doreen

BRISTOL

BRISTOL

Geographical Area number

17

Affidavit - Continued

25. Pedneault accessed Evergreen's QuickBooks files and generated reports identifYing changed or deleted transactions during the period 2007 through 2009. A report comprised of seventeen (17) pages identified voided and/or deleted transactions for the period January through December 2007. A report comprised of twenty (20) pages identified voided and/or deleted transactions for the period January through December 2008. A report comprised of seventeen (17) pages identified voided and/or deleted transactions for the period January through December 2009. Copies of the reports were saved for the files, (referred as Exhibit D) 26. Pedneault's forensic examination determined that within the voided and deleted transaction reports their were deleted invoices for customers Pomposi and Avancha, and many other customers with voided or deleted invoices and transactions.

27. In one instance, invoice #42068 was added into QuickBooks for customer Pomposi on June 23, 2009.

Subsequently, the invoice was deleted on July 1, 2009. The user name associated with the deleted invoice was "Doreen". I learned from Mrs. Kuhr that user name "Doreen" was assigned to Milewski. Pedneault generated a complete history of sales and collection activity for customer Pomposi. Invoice #42068 did not appear on the history report. Copies of the transactions were made (Referred as Exhibit E).

28. In another instance, invoice #42680 was added into QuickBooks for customer Avancha on September 30, 2009 at 8:42 a.m. Subsequently, the invoice was deleted on September 30, 2009 at 1:42 p.m. The user name associated with the deleted invoice was "Doreen". Pedneault learned from Mrs. Kuhr that user name "Doreen" was assigned to Milewski. Copies of the transactions were made (Referred as Exhibit E).

29. Many other examples of deleted invoices were found associated with user name "Doreen." Procedures were performed to identifY if issues existed within those customer's history and balances, but due to limitations on information maintained within each customer's files, no further customers were identified that could be quantified.

30. Pedneault generated customer histories for the period January 2007 through December 2009 for customers Giammatteo, Avancha and Kandarpa. Using the first identified deposit difference provided by Mrs. Kuhr dated September 18, 2009 reflecting a payment of $1,000 from customer Avancha, Pedneault was able to trace the $1,000 amount per the Daily Receipt Sheet to the posted payment of $1,000 within QuickBooks (Referred as Exhibit F).

(This is page 6 of a 18 page Affidavit.)

Date

Signed (Affiant)

Signed (

Jurat

QJ.

ARREST WARRANT J.l.PPUCATION JD-CR-64a Rev. 1-11 C.G.S. ยง 54-2a Pro Bk. Sec. 36-1, 36-2, 36-3

STATE OF CONNECTiCUT SUPERIOR COURT www.jud.cLgov

Name (Last, Firs/, Middle Initial)

Residence (Town) of accused

Court to be held at (Town)

MILEWSKI, Doreen

BRISTOL

BRISTOL

Geographical Area number

17

Affidavit - Continued

31. Using the same deposit details for September 18, 2009, Pedneault identified that the Deposit Receipt Sheet reflected a payment of $1,000 from customer Avancha, a deposit from customer Dabrowski for $296.80 and a payment from customer Krar for $253.25. The total of the deposit was $1,550.25. However, the deposit slip for the same day reflecting the same total ($1,550.25) only reflected two deposit items, $296.80 and $1,253.45.

Further, the deposit detail provided by Evergreen's bank to Mrs. Kuhr supporting the deposit for that day was comprised of a check from customer Dabrowski for $296.80 and a check from customer Krar (#1617) for $1,296.80. Pedneault concluded that the payment from customer Krar was inappropriately split between customer Krar ($296.80) and customer Avancha ($1,000), and therefore customer Krar was not properly credited for the full payment made.

32. Based on training and experience, Pedneault assessed this inappropriate allocation of one customer's payment (Krar) to a different customer (Avancha) as a classic sign of a "lapping" scheme, whereby one customer's payment is used to conceal the diversion of funds from a different customer's payment, typically a customer who paid in the form of cash. Given the fact that customer Avancha paid Evergreen in cash, this further supports his assessment that the application of the payment from customer Krar to customer Avancha was a classic sign that a lapping scheme was perpetrated by someone with access to the customer payments received at Evergreen as well as Evergreen's QuickBooks system (Referred as Exhibit G).

33. Using the deposit details for September 4, 2009, Pedneault identified that the Deposit Receipt Sheet reflected two payments ($950.00 and $900.00) from customer Avancha, as well as four other customer payments.

The total of the deposit was $2,345.38. However, the deposit slip for the same day reflecting the same total ($2,345.38) only reflected five deposit items. Further, the deposit detail provided by Evergreen's bank to Mrs. Kuhr supporting the deposit for that day was comprised in part of a check from customer Hagstrom (#1664) for $948.82 and a check from customer Cormier (#5043) for $901.00. Neither customers Hagstrom nor customer Cormier were included on the Deposit Receipt Sheet.

34. Pedneault concluded that the payments from customers Hagstrom and Cormier were inappropriately allocated to customer Avancha ($950.00 and $900.00), and therefore customers Hagstrom and Cormier were not properly credited for the full payments made.

35. Based on training and experience, Pedneault assessed this inappropriate allocation of customer's payments (Hagstrom and Cormier) to a different customer (Avancha) as another classic sign that a "lapping" scheme was perpetrated by someone with access to the customer payments received at Evergreen as well as Evergreen's QuickBooks system (Referred as Exhibit H).

(This is page 7 of a 18 page Affidavit.)

Date

Jurat

Signed (Affiant)

ARREST WARRANT APPUCATION JD-CR-64a Rev, 1-11 C,G,S, ยง 54-2a Pr, Bk, Sec, 36-1, 36-2, 36-3

STATE OF CONNECTICUT SUPERIOR COURT www,jud,ct.gov

Name (Last, First, Middle Initial)

Residence (Town) of accused

Court to be held at (Town)

MILEWSKI, Doreen

BRISTOL

BRISTOL

Geographical Area number

17

Affidavit - Continued

36. Using the deposit details for August 5, 2009, Pedneault identified that the Deposit Receipt Sheet reflected a payment of $1,484.00 from customer Avancha. The total of the deposit was $1,484.00. The deposit slip for the same day reflected the same total ($1,484.00). However, the deposit detail provided by Evergreen's bank to Mrs. Kuhr supporting the deposit for that day was comprised of a check from customer Balkus (#5969) for $1,484.00.

Pedneault concluded that the payment from customer Balkus was inappropriately allocated to customer Avancha ($1,484), and therefore customer Balkus was not properly credited for the full payment made.

37. Based on training and experience, Pedneault assessed this inappropriate allocation of one customer's payment (Balkus) to a different customer (Avancha) as another classic sign that a "lapping" scheme was perpetrated by someone with access to the customer payments received at Evergreen as well as Evergreen's QuickBooks system (Referred as Exhibit I).

38. Mrs. Kuhr provided Pedneault with the original deposit details and support for every deposit she identified with a difference in the deposit items (Refered as Exhibit J). Pedneault secured the information as evidence, logged and labeled the information, and later that day he secured the information within Pedneault's firm's evidence room. Subsequently the information was scanned on-sight into PDF files for reporting purposes, and the original evidence was returned into the evidence room.

39. On August 24, 2010 Pedneault returned to Evergreen and met with Mrs. Kuhr. Mrs. Kuhr provided him further information for the identified customers as well as access to Evergreen's QuickBooks records.

40. Mrs. Kuhr provided Pedneault with the original documents evidencing Evergreen's performance of work for customers Pomposi, Avancha, Giammatteo and Kandarpa (Referred as Exhibits K through N). Pedneault secured the information as evidence, logged and labeled the information, and later that day Pedneault secured the information within his firm's evidence room. Subsequently the information was scanned on-sight into PDF files for reporting purposes, and the original evidence was returned into the evidence room.

41. At Pedneault request, Mr. Kuhr contacted customer Pomposi to inquire how Mr. Pomposi paid for the work performed by Evergreen with invoice #42068 dated June 23, 2009. Invoice #42068 was deleted from Evergreen's QuickBooks under user ID "Doreen" and no trace of customer Pomposi's payment had been located. Mr. Kuhr indicated customer Pomposi stated he paid cash for the work performed by Evergreen for invoice #42068. Mr. Kuhr indicated customer Pomposi was well known to Mr. Kuhr as Evergreen had completed a lot of work for him in the past.

(This is page 8 of a 18 page Affidavit.)

Date

Jurat

Signed (Affiant)

ARREST WARRAI\IT APPliCATION JD-CR-64a Rev. 1-11 C.G.S. ยง 54-2a Pro Bk. Sec. 36-1, 36-2, 36-3

OF CONNECTICUT SUPERIOR COURT www.jud.ct.gov

Name (Last, First, Middle Initial)

Residence (Town) of accused

Court to be held at (Town)

MILEWSKI, Doreen

BRISTOL

BRISTOL

Geographical Area number

17

Affidavit - Continued

42. Based on the information provided in the form of deposit details as described above, it appears Evergreen sustained a loss through an embezzlement perpetrated through a scheme commonly known as lapping. Under such a scheme, customer payments, typically paid in cash, are inappropriately diverted from the company as they are received. To conceal the scheme and diversion, payments received from other unrelated customers are posted and applied to the customers whose payments were diverted. These elements existed within Evergreen as described above. The customers identified by Mrs. Kuhr were all cash paying customers, and evidence of work performed by Evergreen without corresponding payments received from those customers were a sign that a theft was perpetrated.

43. Evergreen utilized QuickBooks for their accounting system, including the invoicing of customers and the recording of customer payments. Users were established by Evergreen within QuickBooks. However, other features of QuickBooks were never fully utilized by Evergreen that would have limited what each user had access to and what types of activity each user could perform within QuickBooks. Therefore, users were able to utilize the full functionality of QuickBooks at Evergreen, including the subsequent changing, voiding and deleting of transactions. Evidence of large amounts of transactions being changed, voided and/or deleted, including invoices, was found on Evergreen's QuickBooks system, revealing another sign that embezzlement likely occurred at Evergreen that was concealed by changing, voiding and/or deleting transactions within QuickBooks.

44. Based on the condition of the customer files and missing information, coupled with voided and/or deleted transactions within QuickBooks and the lapping of customer payments, the full amount of the loss likely sustained by Evergreen will never be determinable.

45. The methodology utilized by Mrs. Kuhr to determine the loss for each identified cash-paying customer appeared reasonable based on the facts and circumstances of this matter. Mrs. Kuhr located and identified every job sheet (a/k/a work order) completed by the field workers at Evergreen when the work was completed for the identified cash paying customers. Using the job sheets, Mrs. Kuhr priced out the work performed based on the proposals provided to the customers, consistent with how invoicing was performed all along throughout the years

by Mrs. Kuhr.

(This is page 9 of a 18 page Affidavit.)

Date

Signed (Affiant)

Signed (

Jurat Reviewed (Prosecutori

((

ARREST WARRANT APPUCATION

OF CONNECTICUT SUPERIOR COURT

JD-CR-64a Rev. 1-11 C.GS. § 54-2a Pro Bk. Sec. 36-1, 36-2, 36-3

www.jud.ct.gov

Name (Last, First, Middle Initial)

Residence (Town) of accused

Court to be held at (Town)

MILEWSKI, Doreen

BRISTOL

BRISTOL

Geographical Area number

17

Affidavit - Continued 46.

Based on Mrs. Kuhr's procedures, the following were losses incurred by Evergreen for the identified customers: • Pomposi $ 5,760 • Avancha $ 8,852 • Giammatteo $ 2,580 • Kandarpa $ 16,829 Total $ 34,021

47. Pedneault provided a copy of his draft report to Mrs. Kuhr and instructed her to review it carefully.

Pedneault spoke with Mrs. Kuhr on September 27, 2010. Mrs. Kuhr indicated she and Mr. Kuhr had reviewed the report in detail, and provided Pedneault two changes to the dates of employment for Milewski. Mrs. Kuhr indicated she and Mr. Kuhr were in agreement with the remainder of the draft report.

48. Using the information for each identified procedure above, Pedneault estimated the loss sustained by Evergreen as follows: 1. Pomposi $ 5,760 2. Avanta 8,852 3. Giammatteo 2,580 4. Kandarpa 16,829 $ 34,021 49. Based on the procedures described above and the results of those procedures, it appears Evergreen suffered a loss approximating $34,021 through the theft of customer cash payments. While a loss was determined and calculated based on identified transactions, it is highly likely that additional theft occurred, with the additional diversions concealed within Evergreen's records. Records were only reviewed for the three-year period 2007 through 2009. It is unknown if thefts were occurring prior to 2007. However, based on the knowledge known to date, no additional procedures are contemplated or requested by Evergreen on this matter.

(This is page 10 of a 18 page Affidavit.)

Signed (Affiant)

Date

Signed

Jurat

Q!-

Reviewed (Judgelfidge

,.

"

ARREST WARRANT APPLICATiON JD-CR-64a Rev. 1-11 C.G.S. ยง 54-2a Pro Bk. Sec. 36-1, 36-2, 36-3

STATE OF CONNECTi.CUT SUPERIOR COURT www.jud.ct.gov

Name (Last, First, Middle Initial)

Residence (Town) of accused

Court to be held at (Town)

MILEWSKI, Doreen

BRISTOL

BRISTOL

Geographical Area number

17

Affidavit - Continued 50. The listed exhibits provide the details of the results from Pedneault's procedures. The exhibits are provided electronically on a CD within the case file. A listing of all exhibits is listed below.

Listing of Exhibits (provided electronically via enclosed CD) A. B. C. D. E. F. G. H.

Customer John Fontana Information Evergreen letters to Avancha, Kandarpa and Giammatteo Farm Family Insurance Company Loss Claim Voided/Deleted Transactions - QuickBooks Deleted Transactions - Pomposi and Avancha invoices QuickBooks history reports - customers Giammatteo, Avancha and Kandarpa Deposit details September 18, 2009 Deposit details September 4,2009 1. Deposit details August 5, 2009 J. Identified deposits with differences K. Supporting job sheets and other information - customer Pomposi L. Supporting job sheets and other information - customer Avancha M. Supporting job sheets and other information - customer Giammatteo N. Supporting job sheets and other information - customer Kandarpa O. Schedule of Estimated Loss 51. On October 19,2010 Carol Ann Giarnrnatteo (DOB 12/31/41) of 66 Sabina Dr came to the Southington Police Department and gave a signed sworn statement explaining how she made payments for work conducted by Evergreen Nursery. Giarnmatteo stated how she had work services conducted by Evergreen Nursery and after their services were complete she would always pay them in CASH. Giammatteo said that whenever she would pay Evergreen Nursery she would bring CASH monies to their place of Business at 567 Woodruff Street. She would pay the clerk at the garden department register and lor sometimes, maybe twice, pay at the office. The names of the workers she gave my CASH monies to are Doreen Milewski (about two or three times) and a worker named Heidi (Unknown last name), an employee at the garden center register. Giammatteo said she would primarily give the cash monies to Heidi or whoever was working at the cash register. Giarnmatteo added that whenever she would pay cash monies to them she would have the employee sign her invoice as "PAID" and date the invoice. In addition, Giarnrnatteo provided three invoices that clearly marked "Paid in Full Cash". The invoices she provided are:

(This is page 11 of a 18 page Affidavit.)

Date

Signed (Affiant)

Jurat Reviewed (JUdgeIJUdZFri?' Referee)

--; . '1--.

..

ARREST WARRANT APPUCA TION JD-CR-64a Rev. 1-11 C.G.S. ยง 54-2a Pro Bk. Sec. 36-1, 36-2, 36-3

STATE OF CONNECTICU'T SUPERIOR COURT www.jud.ct.gov

Name (Last, First, Middle Initial)

Residence (Town) of accused

Court to be held at (Town)

MILEWSKI, Doreen

BRISTOL

BRISTOL

Geographical Area number

17

Affidavit - Continued a, Invoice # 41707 dated 5/19/2009, PAID on 5/26/09 and signed with initials and marked "Paid in Full Cash", Amount of$54,06 b. Invoice # 42828 dated 9/25/2009, PAID on 9/28/09 and marked "Paid CASH in Full" and signed with initials, Amount $54.06 c, Invoice # 43256 dated 11/16/2009, PAID on 11/20/09 and marked "Paid full Cash" Amount $ 424.00 52. Giammatteo does not have any other invoices among her records concerning Evergreen Nursery stating she may have shredded them. These original invoices were placed in this case file for further references during this investigation. Giammatteo stated that to the best of her knowledge, Evergreen Nursery's records should reveal that she has no outstanding or current invoices claiming that she owes monies for services. Giammatteo believes that her status with Evergreen Nursery is "Paid in Full" on all past invoices.

53. On November 23,2010 Phil Pomposi (DaB 2/1/35) of 1215 Pleasant St. Southington, CT came to the Southington Police Department and gave this AFFIANT a signed sworn statement stating that he does business with Evergreen Nursery. Pomposi stated that he paid Evergreen Nursery. He explained that he hired Evergreen to cut trees down in 2009. Pomposi said he still has the invoice for their work in his records which he forwarded a copy to this AFFIANT for this investigation. The invoice dated June 23, 2009, number 42068, shows that Pomposi paid Evergreen Nursery on June 30, 2009 the sum of$1,300.00 dollars. Pomposi said he paid this amount to Mr. Kuhr in cash. Mr. Kuhr then wrote "Paid in full" on the invoice and signed his name. Currently the only other business he has with Evergreen Nursery is that they fertilize his lawn at 1215 Pleasant St. Pomposi states he pays for these services by check which he mails to Evergreen Nursery. Pomposi stated he normally pays for a year's worth of services at a time by check.

54. On November 30, 2010 Murthy Kandarpa (DaB 8/26/71) of215 Mountain Pond Rd Southington, CT came to the Southington Police Department and gave this AFFIANT a signed sworn statement stating that he did business with Evergreen Nursery. In March of2002 Kandarpa started having outside landscaping work done at his home at 215 Mountain Pond Rd. Southington, CT. He hired Evergreen Nursery to do the irrigation system and seeding of his lawn for a cost of approximately 8,000.00 dollars. After that he hired Evergreen Nursery to do the annual maintenance of the irrigation system, install plants, and to mow his grass on occasion. This cost him about 2,000.00 per year. In 2003 he again hired Evergreen Nursery to install the landscaping all the way around his home. That cost him about 6,000.00 dollars.

(This is page 12 of a 18 page Affidavit.)

Date

Jurat

Signed (Affiant)

ARREST WARRANT APPUCATiON JD-CR-64a Rev. 1-11 C.G.S. ยง 54-2a Pro Bk. Sec. 36-1, 36-2, 36-3

STATE OF CONNECTiCUT SUPERIOR COURT www.jud.ct.gov

Name (Last, First, Middle Initial)

Residence (Town) of accused

Court to be held at (Town)

Geographical

MILEWSKI, Doreen

BRISTOL

BRISTOL

Area number

17

Affidavit - Continued 55. Kandarpa stated that during the first two years of doing business with Evergreen he paid Mr. Kuhr directly in cash when he would visit his home requesting payment for the services. He remembers counting the cash payments with Mr. Kuhr. Mr Kuhr would ask that he pay periodically after a certain amount of work was completed. After the year 2002 Mr. Kuhr told Kandarpa he could pay any further payments to Buddy ( The Evergreen Site Work Foremen), Doreen (The Office Manager) or Mary (The Office Bookkeeper).

56. Kandarpa stated that starting in 2005 he started paying Doreen and Mary for Evergreen Nursery services.

Kandarpa never paid "Buddy" any cash. Kandarpa would pay Evergreen Nursery in cash whenever he needed to pay them. Doreen and/or Mary gave me him receipt but he never saved it. Kandarpa doesn't always keep receipts.

Since he started paying cash to Doreen and Mary he estimated that he paid them about 16,000.00 dollars total before ending his services with Evergreen Nursery.

57. Kandarpa said the cash he paid to Evergreen Nursery would come from cash withdrawals from his savings account or from a cash advance from his credit card. Kandarpa's Bank is Digital Credit Union in Massachusetts.

Kandarpa attempted to contact them for receipts and or documents concerning the transactions and was told they would research his withdrawals and if records can show them they will forward these documents to him.

Kandarpa has not received any documents from them.

58. Kandarpa said in 2008 he had Evergreen Nursery do work in the back yard around a shed and Evergreen billed him 8,000.00 dollars for the work. The work included some plants and general landscaping. Kandarpa learned that Mr. Kuhr had open heart surgery. It was afterwards that he started having problems with Evergreen Nursery. Kandarpa said he was accused of not paying them. He sated he did pay Evergreen. He sated he paid CASH to them. Kandarpa said he paid Doreen and Mary cash for the services. Kandarpa said he explained to Mr Kuhr that he paid Evergreen Nursery in cash like he always has in the past. Mr Kuhr later advised him that he agreed he received payment in cash and told him he had an internal paperwork issue that he was looking into and apologized to him for the misunderstanding.

(This is page 13 of a 18 page Affidavit.)

Date

Signed (Affiant)

Jurat

(

ARREST WARRANT APPLICATION

STATE OF CONNECTiCUT SUPERIOR COURT

JD-CR-64a Rev. 1-11 C.G.S. ยง 54-2a Pro Bk. Sec. 36-1, 36-2, 36-3

www.jud.ct.gov

Name (Last, First, Middle Initial)

Residence (Town) of accused

Court to be held at (Town)

Geographical

MILEWSKI, Doreen

BRISTOL

BRISTOL

Area number

17

Affidavit - Continued 59. On November 23,2010 Raju Avancha (DaB 8/25/67) of 345 Mount Vernon Road Southington, CT came to the Southington Police Department and gave this AFFIANT a signed sworn statement stating that in the summer of 2009 he hired Evergreen Nursery to install a block concrete retaining wall at his home located at 345 Mount Vernon Rd. Plantsville, CT. The cost of the project was $5,200.00 dollars. When he hired Evergreen Nursery to do the work he agreed to pay in three installments. The first installment was a deposit for materials in the amount of $1,500.00 dollars. Then he paid a second deposit just before the work started in the amount of $1,200.00 dollars. The next payment he made was $2,500.00 for the completion of the job. When he made these payments an employee of Evergreen Nursery named "Doreen" would come to collect the above payments. He paid "Doreen" CASH each time. I didn't get a receipt from Doreen. Doreen told him that she would record his payment and he assumed this was being done. Then about three or more months ago he was contacted by Evergreen Nursery notifYing him that he needed to pay for the services they provided and that he had an outstanding balance due to them in the amount of $5,200.00 dollars. He explained to Evergreen that he paid them in CASH. He explained that he paid a person named "Doreen" who told him that she works for Evergreen Nursery and this was also confirmed by other employees of Evergreen who were doing the work for him. They told him that Doreen was the bookkeeper for Evergreen Nursery. Avancha had bank documents from Bank of America which clearly shows cash withdrawals from his checking account at Bank of America in the amounts stated above. Avancha said the withdrawals were made specifically for payment to Evergreen Nursery. Avancha forwarded these documents to this AFFIANT for this investigation.

60. On December 30, 2010 this AFFIANT called and left messages for both Gionnotti and Milewski advising them that an investigation was being conducted involving Evergreen Nursery and that I needed to speak with them. Gionnotti and Milewski returned calls later that day. When they returned contact I asked that they schedule an appointment with me to talk about this investigation. Milewski stated she would advised me when she could meet I then spoke with Gionnotti who stated she would meet with me on January 4, 2011. Milewski never returned with a date she could meet. On or about January 5, 2011, I contacted Milewski again and she scheduled a date for January 12, 2011 which was changed due to weather conditions. On January 17,2011 Milewski met with me.

61. On January 4, 2011 Mary Gionnotti (DaB 11/22/52) of 2 Burke Heights Dr. Wallingford CT came to the Southington Police Department with her attorney, Attorney Harry Murphy of Maya Murphy PC. Gionnotti agreed to provide this AFFIANT with a signed sworn statement prepared by her attorney within a few days.

62. On January 7, 2011 this AFFIANT received an e-mail from Attorney Murphy containing an electronically scanned statement signed by Gionnotti from him along with (4) four electronic .wav files of recorded messages on her answering machine and cell phone voice mail from Doreen Milewski. (An original copy was mailed and placed in this case file) Gionnotti's statement states the following.

(This is page 14 of a 18 page Affidavit.)

Signed (Affiant)

Date

Signe&-(J~ โ ข

'

, Notary Public)

~-~~_.-

Jurat

Reviewed (JudgelJud9

Date

t "to

It

r

"'<-

ri I Referee)

1/

ARREST WARRANT APPLICATION JD-CR-64a Rev. 1-11 C.G.S. ยง 54-2a Pro Bk. Sec. 36-1,36-2,36-3

STATE OF CONNECTICUT SUPERIOR COURT www.jud.ct.gov

Name (Last, First, Middle Initial)

Residence (Town) of accused

Court to be held at (Town)

MILEWSKI, Doreen

BRISTOL

BRISTOL

Geographical Area number

17

Affidavit - Continued

62a. Mary Giannotti, being duly sworn, herby deposes and says: I am a resident of Wallingford CT, at an address known to the police department of Southington, CT. I worked at evergreen Nursery in Southington fron 2007 through the spring of 2010 as the company's bookkeeper. I was interviewed and hired by Doreen Milewski, who referred to herself as the officer manager. It is my understanding that Doreen worked for Evergreen for approximately 24 years, until the fall of 2009.

62b. During my job at Evergreen, I reported to the owners of the company, Fred and Elke Kuhr. Doreen, who informed me that she was my superior, trained me as to the company's internal procedures and would give me directives to follow from time to time. Shortly after Doreen left Evergreen, I telephoned a customer to follow up on a large outstanding (unpaid) balance, as part of my job duties. That customer, (whose name I cannot recall but was of Indian decent), insisted over the phone that he paid his balance in full by paying cash directly to Doreen. He also said that Doreen had come to his home to retrieve the cash. There was no record of the large amount of cash having been paid by that customer to Doreen or to Evergreen Nursery. Noting that discrepancy and others, and immediately before I went to the owners to report apparent wrongdoing by someone who was my senior at the company (and who had hired me), I contacted and met with the company's accountant and shared with him this and other similar cash discrepancies I had found. The accountant and I met personally with the owners to share the documents I had found. I informed the owners that I believed Doreen was stealing from the company. I urged them on many occasions to contact the police, although they were initially resistant to do so.

62c. While at Evergreen, I very rarely handled any cash, as anyone who paid by cash would give it to Doreen (who sat up front, while I was in the back office). Any and all cash I ever handled was given to Fred. Doreen would typically make all the deposits at the bank in Fred's absence, and I don't believe I ever deposited cash for the company, as that was Doreen's job.

62d. As part of my duties, I would often write up deposit slips for money that came in from customers, in the mail or otherwise. On occasion, Doreen specifically directed me to re-write a deposit slip that she had written herself, using the excuse that she had written it sloppily and she was in a hurry and/or had to leave. Prior to Doreen leaving the company it was her exclusive responsibility to "cost" the jobs, according to job sheets given from the employees, and then invoice the customers. Before Doreen left, I never dealt with job sheets or the invoicing of customers except when I was specifically directed by Doreen or Fred to adjust invoices in order to correct wrong prices or charges originally quoted to clients (for example, if I was instructed that the price of the job had been changed by mutual agreement of Evergreen and the customer). Unless I was specifically directed by the company in these instances, I never once amended or changed any business records. I never deleted any customer accounts, although I believe I uncovered several instances where cash-paying customers' invoices had been entirely deleted and files were missing from Evergreen's records. I shared everything I found with Fred and Elke, who confirmed for me that they believed Doreen had been taking money from the company.

(This is page 15 of a 18 page Affidavit.)

Date

Jurat

Signed (Affiant)

ARREST WARRANT APPLICATiON JD-CR-64a Rev. 1-11 C.G.S. ยง 54-2a Pro Bk. Sec. 36-1, 36-2, 36-3

STATE OF CONNECTICUT SUPERIOR COURT www.jud.ct.gov

Name (Last, First, Middle Initial)

Residence (Town) of accused

Court to be held at (Town)

MILEWSKI, Doreen

BRISTOL

BRISTOL

Geographical Area number

17

Affidavit - Continued

62e. In retrospect, I recall many conversations in which Doreen told me about expensive personal home renovations and remodeling projects. I had wondered at the time how Doreen as a single person could have afforded her lifestyle while earning such a low salary. While I always expected and hoped that Evergreen would contact the authorities with what I had discovered (in fact, Fred had asked me when I left the company if I would be available to confirm everything I had uncovered about Doreen and brought to their attention), I was not contacted by the Southington Police Department until December 30, 2010, when I was told that an investigation of this matter was underway.

62f. Beginning the very next day, on Friday, December 31,2010, Doreen began to call me both at home and on my cell phone. I had not spoken with her at all since she left the company in the fall of 2009, and still have not.

She left several voicemails for me with increasing urgency for me to return her calls; I did not. I have provided the recorded voicemails together with this statement to the Southington Police Department.

63. On January 17, 2011 this AFFIANT met with Doreen Milewski who came to the Southington Police Department at about 1200 hours. Milewski was advised of this investigation. Milewski was asked if while working at Evergreen Nursery, did she alter customer invoices and/or documents. Doreen stated that she had but only when she was requested to do so by Mr. Kuhr, or the company foreman Bill Woods and Kenneth Stakey.

Milewski also stated that Mr. Kuhr's son Eric Kuhr would also request that she alter invoices for customers he was doing business with. Milewski said that whenever an invoice was altered it was to reflect a different balance due as requested by them. Milewski denied ever altering invoices to obtain monies for herself. Milewski was asked why she telephoned Mary Giannotti multiple times before returning contact to this AFFIANT. Milewski stated she wanted to find out from her what was going on and why the police were calling her. Milewski stated after not getting a response from Mary she contacted this AFFIANT. Milewski was asked if she would provide a signed sworn statement regarding her employment at Evergreen Nursery, which she stated "Yes".

63. On January 17,2011 Milewski gave this AFFIANT the following statement: "I worked as a receptionist for Evergreen Nursery. I never made entries into the company Quick-Books financial program. The only time I would use Quick- Books was for contacts regarding billing and invoices. I never altered any billing issues or invoices unless Fred Kuhr, (the owner of Evergreen Nursery) told me to. Fred would say to me that he wanted me to get rid of the invoices and take cash from the business to pay other people and also use it for snow plow money. On other occasions Bill Woods and Kenneth Stakey, both Evergreen Foreman, would tell me the company over-charged the customer too much and to take money off the bill or order me to rewrite the bill. This was the only time I did this. I never did this on my own. The alterations were done in the computer in the QuickBooks program then afterwards I would reprint the new invoice for the customer".

(This is page 16 of a 18 page Affidavit.)

Date

Jurat

Signed (Affiant)

ARREST WARRANT APPLICATION JD-CR-64a Rev 1-11

e.G.s. ยง 54-2a Pr. Bk. Sec. 36-1, 36-2, 36-3

STATE OF CONNECTICUT SUPERIOR COURT www.jud.ctgov

Name (Last, First, Middle Initial)

Residence (Town) of accused

Court to be held at (Town)

Geographical

MILEWSKI, Doreen

BRISTOL

BRISTOL

Area number

17

Affidavit - Continued 63a. ( Statement of Milewski Continued) "There were times when Fred Kuhr and his wife Elke Kuhr would argue over accounts receivables. There were times when Fred would insist on removing an invoice so his "Friends" wouldn't have to pay. His wife Elke would become upset and say they needed to pay like everyone else. Fred would say then agree with Elke then after Elke would leave Fred would tell me to delete the bill and disregard Elke. I never did this on my own for my own financial benefit. Also on other occasions his son, Eric Kuhr would come into the office and tell me to change the bill invoice amount to a lower sum for a customer because it was too much. During my employment with Evergreen Nursery, it was very common for Fred Kuhr, Bill Woods, Eric Kuhr, and Kenneth Stakey to have me delete and or change an invoice claiming that the amount was too high or on rare occasions not enough. I would make these changes for them. That was my job. Also throughout my employment it was very common for Fred Kuhr to take cash. He would often ask me to tell customers that if they paid in cash he would take ten percent or the tax off the bill. I also remember a time when Fred had no money. Fred was bouncing company checks. I believe this was because he was taking cash from the business. I remember that it became so bad that Fred's business was kicked out of Southington Savings Bank".

64... After Milewski gave the aforementioned statement she read the statement. She stated to this AFFIANT and Officer Triano ( a member of this Department ready to notarize the statement) that the statement is correct however she refused to sign the statement. Milewski stated that she wanted to speak to her attorney, unnamed, first. Milewski stated she would advise this AFFIANT after she spoke to her attorney about signing her statement within twenty-four hours. As of January 20, 2010 Milewski has not made further contact with this AFFIANT. 65. The totality of this investigation along with Milewski's interview, actions, and words pertaining to her statement shows an intention to fabricate a false statement to this AFFIANT in the form of a written instrument which she believes to be untrue with total cause to mislead this investigation.

66 ... This AFFIANT searched Milewski's criminal history which reveals no listed criminal activity.

67.. .In conclusion, this AFFIANT believes this investigation reveals clear probable cause showing Milewski altered business documents for her own financial benefit, stealing in excess of $34,021.00 dollars as shown by Forensic Accounting Services, LLC . Stephen Pedneaukt, CPA/CFF, CFE, FCPA, owner of Forensic Accounting Services, LLC has clearly documented evidence of multiple transactions that were altered immediately after CASH was received from cash paying customers identified herein were they state in sworn statements that Cash was given directly to Milewski. The Forensic Audit of Evergreen Nursery's financials clearly show Milewski having specific computer access, knowledge, and opportunity to alter financial business invoices to hide the incoming Cash and allocate balances among other Evergreen Nursery customers at the time Cash was received.

Milewski's own admission states she altered financial records within Evergreen Nursery's accounts receivable and payable records but states she only did this upon the request of others, including the owner of Evergreen Nursery, who is the victim within this investigation.

(This is page 17 of a 18 page Affidavit) Date

Signed (Affiant)

Jurat

I I

II (! ! I

ARREST WARRANT APPUCATION JD-CR-64a Rev. 1-11 C.G.S. 搂 54-2a Pro Bk. Sec. 36-1. 36-2, 36-3

STATE OF CONNECTiCUT SUPERIOR COURT www.jud.ct.gov

Name (Last, First, Middle Initial)

Residence (Town) of accused

Court to be held at (Town)

MILEWSKI, Doreen

BRISTOL

BRISTOL

Geographical Area number

17

Affidavit路 Continued

68 ... It is requested that an arrest warrant be issued for Doreen MILEWSKI (DOB 11111/56) of 53 Sand Hill Rd Bristol, Connecticut for being in violation of the Connecticut General Statues, 53a-122; Larceny }St degree, 53a-139; Forgery 2nd Degree, and 53a-157b; False Statement 2nd Degree, as stated, during her employment with Evergreen Nursery from 2007 through 2009.

(This is page 18 of a 18 page Affidavit.)

Date

Signed (Affiant)

Signed (

Jurat

IQuL..