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STATE OF INDIANA IN THE MARION SUPERIOR MARION COUNTY, ss: CRIMINAL COURT 25

CRIMINAL DIVISION, ROOM W343

STATE OF INDIANA Cause No: 49G25—1608—F6—032934

INFORMATIogi'IL ED COUNT I VS.

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THEFT AU ,

Tia Joseph ”Female LC. 35-43420.) and 1.66 fsgflifi-nflflm DOB 7/20/1979 A LEVEL‘mQNEA Z!

; 44a GI

On this date, the undersigned came before the Prosecuting Attorney of the Nineteenth Judicial Circuit and, being duly sworn (or having affirmed), stated that in Marion County, Indiana

COUNT I

On or about July 16, 2015, Tia Joseph did knowingly exert unauthorized control over the property

of Jug's Catering, to-wit: United States currency, with the intent to deprive Jug's Catering of any part of

the use or value of the property, said property having a value of at least seven hundred fifty dollars and

less than the value of fifiy thousand dollars;

all of which is contrary to statute and against the peace and dignity of the State of Indiana.

I swe r affirm under penalty of perjury as specified by LC. 35-44.1-2-l that the foregoing represe ons are true.

Au t23 2016 Afiia‘nf

v Date

TERRY R. CURRY State's Witnesses: Marion County Prosecutor Jug's Catering 19th Judicial Circuit D. Boehmer OIG 0006 Teresa Brown Lisa Acobert Tracy Brown Deputy Pro cu

‘

Jen Colson Evan Eckert Heather Baker Nick Turner

8/23/2016 10:34 AM

STATE OF INDIANA ) IN THE MARION SUPERIOR COURT ) SS: CRIMINAL DIVISION

COUNTY OF MARION ) CAUSE NO:

IN RE THE MATTER OF AN ARREST WARRANT FOR:

NAME: Tia Larianna Joseph IL ED

ADDRESS: 5618 Strearnside Dr. -

Indianapolis IN 46278 AUG " 5 (.iUlOi

SSN: XXX-XX-9563 ‘77., DOB: 7/20/1979 0, 6L 64;

Height: 5’8” Weight: 165 Hair: Black Eyes: Browmamw

PROBABLE CAUSE AFFIDAVIT FOR ARREST WARRANT

The Office of the Indiana Inspector General’s Director of Investigations, Darrell D. Boehmer,

being first duly sworn upon his oath, alleges and says that there is probable cause for an arrest warrant

and would show the Court, to-wit:

1. The person to be arrested is TIA LARIANNA JOSEPH, described more particularly

above.

2. The offenses to be charged are the following:

THEFT, a Level 6 Felony, pursuant to IC 35-43-4-2(a)(2)

3. The probable cause in support thereof is as follows:

Affiant is the Director of Investigations for the Indiana Office of Inspector General (OIG),

Indianapolis, Marion County, Indiana. The OIG is a law enforcement agency established under IC 4-2-

7—2. The OIG is responsible for pursuing criminal investigations in addition to its duties to enforce

Indiana ethics rules and efficiency within the executive branch of Indiana government.

This is an investigation regarding thefl of funds. The Indiana Department of Education (DOE)

tasked Tia Joseph (Joseph), a State employee, with the collection of cash payments for lunch from

attendees at a DOE training event. DOE further tasked Joseph with paying the caterer at the end of the

lunch with the cash payments she collected. Joseph neither paid the caterer nor turned over to DOE the

cash payments she collected at the lunch.

Joseph was an employee of the DOE from Augrst 6, 2013 until her termination on January 8,

2016. Her title at the time of the event in question was Outreach Specialist.

The DOE hosted a Professional Development Seminar on July 16, 2015 at Perry Meridian High

School in Indianapolis, Indiana (hereinafter referred to as the DOE Event). Joseph, as part of her duties,

arranged for Jugs Catering of Indianapolis (Jugs) to provide a meal for the attendees of the seminar. It

was also her responsibility to collect cash payments for the lunch from the attendees and pay the caterer

with the money she collected.

A second DOE employee, Ebony Uloho (Uloho), who was also assigned to the seminar, stated

that both she and Joseph collected the lunch fees, which attendees were to pay in cash. When Joseph and

Uloho collected the money, they both counted the money and placed it into a small box. Joseph was to

pay the caterer.

Heather Baker (Baker), the DOE employee who was in charge of the event and Joseph’s

supervisor, advised Affiant that Joseph was responsible for arranging the catering, collecting the money,

and paying the caterer. Baker also advised that Joseph told her that the caterer had been paid at the

conclusion of the event. Baker further advised that any money that exceeded the catering bill would be

used for refreshments for the next DOE event.

The invoice obtained from Jugs showed that one-hundred and fifty (150) meals were served at a

cost of twelve dollars and fifty cents ($12.50) per meal, for a total cost of eighteen hundred and seventy

five dollars ($1,875.00). An email from Baker to Joseph contained an agenda for the DOE Event. The

email advised that lunch would cost fifteen dollars ($15.00) per attendee and that attendees would need

to pay for the lunch in cash. The email chain also included an email to fourteen other DOE employees

indicating that lunch would cost them seven dollars ($7.00). Of the 150 people who received lunch at

the training, fifieen (15) people, including Baker, paid seven dollars ($7.00) for their lunch, totaling one

hundred and five dollars ($105.00). The remaining one hundred and thirty five (135) people paid fifteen

dollars ($15.00) for their meals, for a cash total of two thousand and twenty five dollars ($2,025.00).

Based on the number of meals listed on the invoice from Jugs and the fees set by the DOE, the total cash

payment that should have been collected that day was two thousand one hundred and thirty dollars

($2,130.00).

On October 1, 2015, Jugs Agent, Jen Colson (Colson), contacted Joseph by email requesting that

Joseph contact Jugs regarding the unpaid invoice for the DOE Event. She wanted to discuss payment.

On October 8, 2015, Colson emailed Joseph again and asked for a response.

On October 8, 2015, Joseph replied to Colson by email and stated she thought the invoice for the

DOE Event had been paid and that she would check with the DOE’s Finance Department.

Colson advised Afflant that Joseph was to drop off payment for the invoice at Jugs on November

3, 2015, but she did not make the payment. In an email on December 2, 2015, Colson referenced a

conversation between Joseph and former Jugs Employee, Claire, in which Joseph was to deliver the

payment on November 3, 2015.

On December 4, 2015, Colson, at Joseph’s request, emailed Joseph an updated invoice for the

DOE Event listing Joseph as the person being billed. The email included a credit card authorization form

so that Joseph could pay the bill with her personal credit card.

On December 14, 2015, Colson emailed Sara Henry (Henry) at the DOE and explained that she

was unable to collect on a past due invoice for the DOE Event.

On December 14, 2015, Joseph emailed Henry that Colson was going to call her back that

afternoon. She further advised that she would contact Henry as soon as it was resolved and that she

would come down afier lunch to fill her in.

On January 5, 2016, Colson emailed Tracy Brown (“Brown” , a DOE employee, about the

unpaid invoice. Brown responded that the DOE was trying to unravel the situation.

On January 6, 2016, Brown responded to Colson via email indicating that Joseph had stated that

the bill had been paid in full and that she had a receipt.

On January 7, 2016, Lisa Acobert (Acobert), a DOE employee, told Joseph that the “receipt” that

she had provided Brown was not a receipt, but instead was an invoice from Jugs dated July 17, 2015.

Acobert obtained a copy of the invoice that Joseph presented as proof of payment. The payment

details section on this invoice had a dot inside the circle next to Cash. The copy of the invoice obtained

from Jugs did not have the same marking. Colson advised Affiant that this would not have been marked

at Jugs. A copy of the original invoice #07162015, which was obtained from Colson, was dated Ju]y 17,

2015 and did not have the cash payment notation that the invoice turned in by Joseph contained.

On January 7, 2016, in an email to Acobert, Joseph wrote, “That was all I have from them . . . I

know that I paid and what was given back to me. I apologize for any confusion but will rectify this as

needed . . . They were the only vendor not willing to take payment on site.” She further wrote that she

thought the invoice was a receipt and she accepted responsibility for not getting a receipt.

Brown stated that Joseph had told her Jugs would not take payment on-site and that she had to

return to Jugs the day after the DOE Event to make the payment.

On June 29, 2016, Affiant asked Colson via email if she could determine whether Joseph had

made arrangements with Jugs to cater the DOE Event by email, phone or in person. Colson responded,

“[w]e typically don't have clients in the office. Based on her correspondence with Carla it was all done

via email and phone. It is EXTREMELY rare that people book events in person unless it's a wedding.”

On June 30, 2015, Affiant met with Evan Eckert, owner of Jugs. Eckert advised that he,

personally, had catered the DOE Event at Perry Meridian High School. Affiant showed Eckert a Jugs

catering worksheet provided by Colson and he identified the worksheet as the sheet he made notes on

about the food for the DOE Event. He also stated that he would have made a note on the worksheet if payment had been collected on-site. He further advised that he would have accepted cash payment for

the catering services provided if someone had offered to pay at that time on—site. Eckert turned in the

catering worksheet to his business office for billing at the conclusion of the DOE Event,

Affiant has based this probable cause on regularly maintained business records, DOE emails and

interviews with persons with personal knowledge of the events.

For all of the above reasons, I am requesting the issuance of an arrest warrant for Tia Larianna

Joseph. The total dollar amount for the theft itemized in this affidavit is two thousand one hundred and

thirty dollars ($2,130.00) and Official Misconduct I swear or affirm under penalty of perjury as

specified by IC 35-44.1-2-1 that the foregoing representations are true.

Dated thisa day of Au; “5 f 2016., Darrell D. Boehmer, Special Agent Indiana Office of Inspector General 315 West Ohio Street, Room 104

Indianapolis, IN 46202

Subscribed and sworn to before me, this y of , 20/;

Judge, Superior Court Criminal Deputy Prosecuting Attorney Division, Marion County, Indiana Nineteenth Judicial Circuit