Guillet Warrant

8/3/2019 Guillet Warrant

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STATE OF CONNECTICUTSUPERIOR COURTwwwjud.d.govPolice Case10-00033816

(Lasl Firsl GeographicalArea numberGuillet, KarenApplication For Arrest WarrantTo: A Judge of the SuPerior CourtThe undersigned hereby applies for a warrant for the of the above-named accused on the basis of the factsset forth in the: X AffidavitOete u Q3- name olAffidavitThe undersigned affiant, being duly $worR' deposes and says:

1) That the affiant, Detective Josh Pattberg#73l, is a member of the Connecticut State Police, and has beenemployed by said department since 2004. The affiant is currently assigned to the Western District MajorCrime Squad at Troop A in Southbury, and as a detective in this unit is tasked with handling criminalinvestigaiions involving, but not limited to, homicides, serious sexual assaults, serious physical assaults,financial crimes and investigations otherwise deemed complex in nature. The affiant has receivedtraining specific to financial records examination and analysis through the National White Collar CrimeCenter. In the course of investigating said matters, the affiant has authored and co-authored arrest andsearch and seizure warrants. The facts and circumstances contained hereinafter are the result ofinvestigation by the affiant and information received from other law enforcement officers acting in theirofficial capacity.

2) On 0l/l9ll0, Sergeant Kline #142 and I met with Oxford Town Attorney Francis Teodosio" Teodosiogave us a brief overview and supplied us with documents relevant to a suspected larceny that wasoccuning at Oxford Town Hall. Teodosio stated the Town Tax Collector Karen Guillet, has been accused9f stealing town funds and has been placed on administrative leave.

3) Teodosio stated on 12/01/09 he received a phone call from a fellow attorney named George Temple.Temple stated one of his clients informed him that the Oxford Tax Collector was stealing from the town.Assistant Tax Collector Sharon Scinto also provided information to First Selectrnan Mary Ann Drayton-Rogers about Guillet taking proceeds from the tax office.

This is page 'l of a 27 page Aftidavit.)

Finding

ARREST WARRANT APPLICATIONJD-CR-64b Rev. 3-1 1C.G.S. $ 54-2aPr. Bk. Sec. 36-1, 36-2, 36-3

Giuanie of a wanant for the arrest of the above-named accused.Date andSignature

The forego.ing Application for an arrest warrant, and affidavit(s) attached to said Application, :eljt3"ffi:?"t[!1ru$:tn*&'ndiJn.iA"rEO n-V itiiunOersigned, the undersigned finds from said affidavit(s) th.at the.re.is pt; ;ff;;hjs been comriitteci inairrit-trdlciuieo committeo it and, thtirefore, that piobable cause exists for the

For Court Use OnlySupporting Affidavits sealedIves INo

CT State Police-Western District Major Crime Squad

Trial Referee


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ARREST WARRANT APPLICATIONJD-CR-64a Rev- 3-11C.G.S. S 54-2aPr. 8k. Sec. 36-1. 36-2. 36-3Name

STATE OF CONNECTICUTSUPERIOR COURTwww.jud.ct.govGuillet, Karen GeooraDhicalArea"number 5Affidavit - Continuedvalidation on the back of the deposit slip. Scinto stated the bank's typed validation said "Checking

Commercial Account" when the bank's normal validation says "Checking Commercial Deposit" and theletters seemed larger and the spacing was off. Scinto also stated the validation on the check reflectsnfi.0109 at 1:33:04. Scinto stated she did not fill out the deposit slip until approximately 4:00 P.M. onllll0l09, making a deposit at 1:33:04 impossible. Scinto stated the earliest the deposit could have beenmade would have been 1lll2l09, due to the banks being closed for Veteran's Day on 11/11/09. Scintostated Guillet's demeanor became very strange. Guillet then stated she would go to the bank Friday andstraighten the matter out. The following Tuesday it appeared to Scinto that Guillet had not done anythingto remedy the situation. Scinto stated she brought this incident to the affention of First SelectmanDrayton-Rogers and Town Attorney Teodosio on L2l0Ll09. Scinto provided us with copies of thefraudulent deposit ticket, the computer generated transaction deposit slip, and the receipt tape associatedwith the batch report. Scinto initialed and dated these four (4) items as being accurate representations ofthe actual documents.

9) Scinto stated after she reported the incident from November 2009 to the first selectman and town attorneythey told Guillet there would be a meeting and recommended she bring iepresentation (legal) with her.Scinto further stated at that time Guillet began cleaning out her desk and tlrowing papers away. Scintostated the tax ofhce was kept in disarray. She stated there were boxes of deposit slips, batch reports, andvalidation slips everywhere.

10) Scinto stated it was common to find random tax payer checks throughout the office. Scinto recalled timeswhen she has seen some of the checks she processed in the cash box and then questioned Guillet about thebatch being in balance despite the missing number of checks. Scinto stated Guillet would respond statingthe checks musfhaVe gotten mixed up, the totals must have been flre same and everything worked out.

I 1) Scinto gave examples of checks she observed in Guillet's cash box. She first observed an expired checkfrom Tri-Town Teachers Federal Credit Union in payment of real estate taxes for David Wolf of 7 DavisDrive. Scinto stated the check was validated and showed as paid in the computer system. The closeoutfor the check was 07 /21/08 for the 2007 Grand List. When Scinto looked for the check on l2l3ll09 it wasmissing. Scinto supplied us with computer printouts of this issue regarding David Wolfs taxes. Scintoinitialed and dated these three (3) items as being accurate representations of the actual documents.12) In April 2009, Scinto stated she ran out of deposit slips. She went into Guillet's desk and observed twenty(20) to thifty (30) taxpayer checks in the deposit slip box. Scinto wrote a note to Guillet telling her she

found the checks in her desk. The following Monday, Guillet stated to Scinto "Thanks for finding thosechecks-good thing I didn't go to the bank-I would not have balanced."13) Scinto stated Guillet seemed to live a luxurious lifestyle. She stated Guillet spent a lot of money and it

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ARREST WARRANT APPLICATIONJD-CR-64a Rev.3-1 1c.G.S. S 54-2aFr. Bk. Sec. 36.1, 36-2, 36-3

ame (Lssl First. MidCle lnitial)Guillet, Karen

STATE OF CONNECTICUTSUPERIOR COURTwww.jud.ct.govGeooraohicalArea'number 5

Affidavit - Continuedseemed unusual to Scinto for someone with Guillet's salary to be spending that much money. Scintostated Guillet spent money on lavish items such as shoes, purses and vacations worth thousands of dollars.Guillet also told Scinto that her house was paid off. Furtherrnore, Scinto was aware that Guillet put halfof her pay into her retirement plan. Scinto stated she knew this because she (Scinto) used to work inpayroll. Scinto asked Guillet why she puts so much money away and Guillet explained to her that she hada trust fund from her parents, inheritance from her aunt, and father recently sold stocks worth a lot ofmoney.

14) When asked about the Quality Data software used in the tax collector's office Scinto stated the programhas always been easy to use. She further stated if she ever had a problem with the service she would callthe company and they would fix her problem immediately. Scinto stated Guillet always complained ofproblems with the system, but the system always worked fine for Scinto.

15) Scinto stated she and Guillet normally used their own computers, unless they were extremely busy atwhich time they would use each others. She further stated that she and Guillet knew the passwords toeach other's computers. Scinto stated she noticed that Guillet would use her computer while she (Scinto)was at lunch.

16) Scinto stated she would sometimes use the typewriter in the vault to type out addresses on the envelopes.Scinto further stated she did not use mathematical symbols except numerals in the addresses.

17) Scinto stated that prior to April 2009 she did not complete her own closeouts because she was notofficially assistant tax collector yet. Scinto stated she did not go to the bank to make deposits for the taxcollector's office. She frrrther stated the only person who would make deposits lbr the tax collector'soffice was Guillet.

18) Scinto added that Guillet often hired a former Oxford employee named Judith Melko to watch her dogand fold her clothes. Melko told Scinto she has found on occasion bags of deposit slips from the taxcollector's office in Guillefs laundry room. Melko also stated to Scinto she has found large amounts ofcash in Guillet's dresser drawers.

19) Scinto also added it seemed to her that Guillet would often take advantage of only certain people. Shegave an example of a time when a volunteer firefighter paid his taxes in cash. Upon paying his taxesGuillet told him that the computer in the office was not working and she couldn't give him a receipt.Scinto stated that flrreman, whose name she does not remember, now has to repay his taxes while othertaxpayers who have receipts for their cash payments are getting their accounts credited.

20) On 10125/ll, Forensic Science Examiner Greg Kettering lied the affrantwith a lab report stating he

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(This is page 4 of a 27 AtfiQAvit,)

Htq


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ARREST WARMNT APPLICATIONJD-CR-64a Rev.3-11C.G.S. $ 54-2aPr. Bk. Sec. 36-1, 36-2, 36-3

STATE OF CONNECTICUTSUPHRIOR COURTwww.jud.ct.gov(Last Frrst Middle lnitial) GeographicalArea number buillet, Karen

Affidavit - Continuedhas located six (6) captions within the ribbon that appeared to be words, mrmerals and symbols used tofabricate a deposit slip. The dates imprinted on the above six (6) captions are; 1l/I0109, 09124109,07120109,06116109,05/15/09 and 05115109. Of those six (6) captions, he identified the caption used togenerate the initial fraudulent $3,093.42 deposit slip. Kettering stated the ribbon and the knownfraudulent deposit slip were an exact match. Since Guillet had admitted to First Selectman DraytonRogers that she forged the $3,093.42 transaction, it is likely Guillet is to blame for the additional forgerieslocated on the typewriter ribbon. In addition to the ribbon already examined are two (2) additionalribbons that have yet to be examined.

21) Due to the suspected improprieties in the tax collector's office Drayton-Rogers contacted John Accavalloof Michaud and Accavallo, LLC in Ansonia to conduct an audit of the town's records. After an audit ofthe records he was initially given, Accavallo informed Drayton-Rogers that the allegation of fraud in thetax collector's offtce was confirmed.

22) Accavallo conducted an initial audit spanning from l0/U/0g to l2/3t/09. Accavallo found that duringthis time period there was approximately $50,000 of unresolved discrepancies.

23) On 0l/13/I0, a meeting was held with Guillet, Drayton-Rogers, Drayton-Rogers's aide (Joe Calabrese),Teodosio and Accavallo. The meeting was audio recorded with the knowledge and consent of all theparties. Accavallo explained several bank documents and batch reports in which he believed the figureswere questionable. Guillet did not give an assertive answer to the majority of the questions she was askedregarding the suspected transactions. Guillet was shown and confessed to fabricating the deposit slip forthe $3,093.42 and she further stated that she kept the money. Accavallo also asked Guillet if her actionsproceeded October 2009. GuilleT stated they did not. Accavallo then stated that he found another checkwith font not consistent with the font found on a deposit slip generated by the bank. Due to thisdiscovery, Accavallo told Guillet that he would be expanding his audit in search.of additionalimproprieties.

24) Due to the admissions by Guillet, Drayton-Rogers and Teodosio escorted Guillet from the building.Guillet was placed on paid sick leave and was informed that she was not allowed in the tax office.Drayton-Rogers also informed us that before Guillet's departure, during the time the initial audit wasbeing conducted, she was being less than cooperative with the auditor when asked for documents stored inher office. Furthermore, Guillet was reportedly seen throwing paperwork away while the auditor wasconducting the audit. Sergeant Kline and I inquired about the whereabouts of the trash and we wereinformed t'wo (2) dumpster pickups were made after the time Guillet was seen throwing things out.

25) On 02102110, a meeting was held with Guillet, her attorney @dward Giacci), Drayton-Rogers andTeodosio. In the meeting Guillet told Drayton-Rogers her resignation was forthcoming. Restitution was(This is page 5 of a 27 page Atfid4vit.) ll f),rrl , stcna (Affiab.1 I KrtJurat 7""1'"; ;TilT;*re me on (Dare) Stgned ({g!:ge/Clat /,{*t./ ,:r'tr tLl

iewedlBfosedtorial Oflicial) / lDate/1/r/( I r/-:r-r I Revied# UudgeilafigaTiatReferee) | Datellll-* ltt 23'


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ARREST WARRANT APPLICATIONJD-CR-64a Rev.3-11C.G.S. $ 54-2a .Pr. Bk. Sec. 36-1. 36-2. 36-3Name flat,Guillet, Karen

STATE OF CONNECTICUTSUPERIOR COURTwww.jud.ct.govGeographicalArea number 5Affidavit - Continuedalso discussed in this meeting. Guillet indicated that she had $125,000 in town retirement funds that

would be "more than enough" to pay back any missing money. Dralton-Rogers stated there were noagreements made between the two attorneys. Upon leaving the meeting, Guillet told Drayton-Rogers shewas "sorry" and that she had gone to confession and she just wanted "to go away" and never be seenagain. Guillet formally resigned on 06/22/ I0.26) At the direction of the first selectrnan, Accavallo conducted two (2) individual audits of the Oxford TaxCollector's office from 07101/09 to 09130109 and 10/01109 to l2l3ll09. Accavallo's audit includedcomparing the amounts and totals of the batch reports to the transaction deposit slip reports and postedbatch reports. These were then compared to the actual bank deposit slips and the deposits posted to thebank statements from Naugatuck Savings and Loan during these time periods. During the 07101/09 to09/30109 time period there was a total of 108 deposits. The results of the audit are as follows:

a. 93 deposits -The supporting documentation posted batch reports agreed with the transaction slipreportsb. 10 deposits - The auditors were unable to locate tax collection batch reports or transaction depositslips for comparison to deposits as recorded on the bank statements.c. 1 deposit - A tansaction deposit slip dated 07/2ll}9 for $200,438.22 has a record of beingdeposited in the bank as $192,055.18 leaving a difference of $8,383.04. That difference isunexplained/re solved.d. 1 deposit - A transaction deposit slip dated 07129109 for $225,034.40 has a record of beingdeposited in the bank as $224,034.07 leaving a difference of $1,000.33. That difference isunexplained/resolved.e. I deposit - A tax collection batch report and transaction deposit slip dated 08/10/09 for $19g,951.71has a record of being deposited inthe bankas $196,95I.71 leav-ing a difference of $2,000. Thatdifference is unexplained/resolved.f. 1 deposit - A tax collection batch report and toansaction deposit slip dated 0}llz/0g for $1 ll,692.2lhas a record of being deposited in the bank as $111,392.21leaving a difference of $300. Thatdifference is unexplained/resolved.g. I deposit - A tax collector batch report and transaction deposit slip dated 0gl}3l09 for $34,44g.14has a record of being deposited in the bank as $31,239.91 leaving a difference of $3,208.23. Thatdifference is unexplained/resolved.

27) Thesame methods used for the first audit were used for the l0l3ll0g to l2l3ll19audit. During this timeperiod there were a total of 42 deposits. The results of the audit are as follows:

a. 9 deposits - There were no supporting transaction deposit slip reports and posted batch reports.b. 28 deposits - The supporting hansaction deposit slip reports and posted batch reports agreed with


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ARREST WARRANT APPLICATIONJD-CR-64a Rev.3-11C.G.S. $ 54-2aPr. Bk. Sec. 36-1. 36-2. 36*3Name (Lasl

STATE OF CONNECTICUTSUPERIOR COURTwww.jud.ct.govGuillet, Karen GeoqraohicalArea'number 5

the bank deposit.c. I deposit - The deposit slip dated 10/07109 for $13,009.00 has no record of being deposited in thebank.d. 1 deposit - The deposit slip dated 11/05/09 for $44,27L83 has a record of being deposited in the

bank as $37,100.56 leaving a difference of 57,L71.27. That difference is unexplained/resolved.e. 1 deposit - The deposit slip dated lIll0/09 for $30,788.88 has a record of being deposited in thebank as S27,695.46leaving a difference of $3,093.43. That difference is the cash per the originaldeposit slip.f. 1 deposit - The deposit slip and posted batch report dated 11123109 for $35,860.86 has a record ofbeing deposited in the bank as $31,369.83 leaving a difference of $4,491.83. That difference isthe cash per the original deposit slip.g. 1 deposit - The deposit slip report and posted batch report dated 12117/09 for $64,807.43 has arecord of being deposited in the bank as $52,889.57 leaving a difference of $11,917.86. Thatdifference is unexplained/resolved.

28) After Accavallo submitted his report to the town, Drayton-Rogers developed a committee comprised ofJames Hliva (Finance Director for the Town of Oxford), Joseph Calabrese (Administrative Assistant tothe First Selectman), and Jack Kiley CPA (member of the Oxford Board of Finance) as well as other townemployees. The committee's objective was to determine how Guillet was stealing the funds andfacilitating the larceny. With the information gleaned from the process the committee was able to provethat cash was taken from the deposit because the amount of cash on the computer reports did not matchthe cash deposited in the bank. Also, checks were taken from other batches or sources in the tax officeand added to the deposit with the missing cash tornake the deposit balmce. Therefore, the total deposirwould equal the tax records, but the proper accounts were not credited. This process was repeated severaltimes on subsequent deposits and a pattern was developed showing how Guillet would carry out herscheme. This process is commonly referred to as a lapping scheme which is an accouniing method thatinvolves altering the accounts receivable section of the balance sheet with cash that is intended for thepayment of a receivable has been stolen.

29) After the committee identified the type of scheme Guillet was using they proceeded to identiS thelapping scheme through computer generated batch reports (Quality Data), deposit slips, cancelled checks,cash register tape and inquiries to tax payers about the standing of their taxes. The processes required thecommittee to find and retrieve doouments from the poorly organized tax collector's offioe and reconcilethe documents with cancelled checks and validated deposit slips from Naugatuck Valley Savings andLoan. Hliva and Kiley then systematically compiled the figures derived from these documents to outlinethe lapping scheme. The process was very time consuining, but generated an accurate depiction of thescheme from various angles.

Affidavit - Continued



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ARRE$T WARRANT APPLICATIONJD-CR-64a Rev. 3-'1 1C,G.S. S 54-2aPr. Bk. Sec. 36-1. 36-2, 36-3Name flastGuillet, Karen

STATE OF CONNECTICUTSUPERIOR COURTwww.jud.ct.govGeographicalArea number 5

30) The first example generated was batch number 80-21, which received transactions between 08/03/09through 08/11/09. As stated earlier in the affidavit, "80" was the identifuing number associatsd with thebatches Guillet produced and "81" was the identiSring number associated with the batches Scintoproduced. The reason why this batch and date was chosen was because the tax payer's software showedthat Oxford taxpayer Elsie Smith had not paid her tax bill for July 2009. Scinto sent a letter to Smithasking her to send a copy of her cancelled check to town hall. The cancelled check (# 244) showed Smithpaid her taxes on 07/30109. Smith's check cleared, but her tax account had not been credited. Thisprompted Kiley to examine the entire batch and deposit associated with that batch.

31) The batch report and transaction deposit slip totals generated by Quality Data showed there was a total of$231,396.04 in tax credits on 08/13/09. Of that amount, $1,833.11 was cash. However, Guillet'shandwritten deposit slip stated there was only $190.83 in cash. After validation, the bank determinedthere was actually $222.67. This error can likely be attributed to a benign mathematical error on Guillet'sbehalf. Regardless of the amount actually deposited, the difference in the actual amount deposited and thecash listed on the batch report is $1,610.44.

32) To substantiate the lapping scheme, Hliva and Kiley compared the cancelled checks supplied to them byNaugatuck Valley Savings and Loan to batch number 80-21. The total amount of the checks in this batchwas $231,205.2L. This figure added to the fabricated cash amount of $190.83 Guillet listed on the depositslip allows the batch to equal the deposit of $231,396.04 and creates the illusion that the batch and depositfigures match. However, five (5) taxpayers had payments credited to their tax account, but they did notmake a payment on this day, so their payment is not included in this batch. Furthermore, four (4) tax-payers that deposited checks did not have their accounts credited in batch 80-21. This manipulation ofchecks and cash is consistent with lapping.

33) After the method(s) of Guillet's lapping scheme were determined the committee repeated the same steps-disted above for several additional batches. The goal was to show that Guillefs practice had been takingplace for several years, using the same method(s). The following examples are outlined in no specificorder and do not necessarily depict the order in which the committee compiled their data.

34) On LZlL2l07 batch number 80-15 was created and received tuansactions through l2ll8/07. This batchwas chosen because of the large check (#0000057902) from Yankee Gas in ttre amount of $27,278.89 thatwas contained within the batch. The batch report and transaction deposit slip totals generated by QualityData showed there was a total of $91,112.53 in tax credits within the batch. On l2ll9l09, a deposit wasmade to the bank. Of that amounl $4,160.98 was oash per the computer records. However, in Guillet'shandwritten deposit slip stated there was only $29.27 in cash, leaving a cash shortage of $4,131.71.

Affidavit - Qontinued

8 of o 27 page Atfidavit,)


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ARREST WARRANT APPLICATIONJD-CR-64a Rev.3-11C.G.S. S 54-2aPr. Bk. Sec. 3G1, 36-2. 36-3Name (LaslGuillet, Karen

STATE OF CONNECTICUTSUPERIOR COURTwww.jud.ct.govGeooraohicalArea-number 5

Affidavit - Continued35) To substantiate the lapping scheme, Hliva and Kiley compared the cancelled checks supplied to them byNaugatuck Valley Savings and Loan to batch number 80-15. Per the transaction deposit slip the amountof checks that should have been deposited for batch 80-15 was $86,951.55. However, the bank depositslip showed the amount of checks being deposited as $91,083.26. This figure added to the fabricated cashamount of $29.27 Guillet listed on the deposit slip allows the batch to equal the deposit of $91,1 12.53 andcreates the illusion that the batch and deposit figures match. However, thirty-seven (37) taxpayers hadpayments credited to their tax account, but they did not make a payment on this day, so their payment isnot included in this batch. Furthermore, ten (10) tax payers that deposited checks did not have theiraccounts credited in batch 80-15. This manipulation of checks and cash is consistent with lapping.

36) On 0l/31/08, batch number 81-43 was created and later closed on 02103/08. This batch was chosenbecause of a large check (#60356) from Yankee Gas in the amount of 827,957.23. The check wasdeposited into the bank, but credit was not given to Yankee Gas by the Oxford Tax Collector's Office forthe payment. A late notice was sent to Yankee Gas requesting payment and they submitted proo(cancelled check) that the payment had been made. The batch report and transaction deposit slip totalsgenerated by Quality Data showed there was a total of $181,134.90 in tax credits associated with thisbatch. Of that amount, $487.41 was cash. However, Guillet's handwritten deposit slip stated there wasonly $69.18 in cash, leaving a cash shortage of $418.23.

37) To substantiate the lapping scheme, Hliva and Kitey compared the cancelled checks supplied to them byNaugatuck Valley Savings and Loan to batch number 81-43. Per the transaction deposit slip the amounof checks that should have been deposited for batch 81-43 was $180,647.49. However, the bank deposislip showed the amount of checks being deposited as $181,065.72. This figure added to the fabricatedcash amount of $69.18 Guillet listed on the deposit slip allows the batch to equal the deposit o$181,134.90 and creates the illusion that the batch and deposit figures matoh. It should be noted thereappear-s,to be a $1.00 difference between the deposit report and the actual deposit. This can possibly beattributed to a mathematical error. This manipulation of checks and cash is consistent with lapping.

38) Due to these inconstancies specific to Yankee Gas, the committee performed an inquiry into their taxaccount. They discovered the account had been overridden by Guillet on 02128108 and Yankee Gas' taxeswere changed to make the account appear as if they have not paid their $54,557.78 balance. AfteGuillet's scheme was uncovered and she resigned from Oxford Town Hall, Scinto sent delinquent noticesto residents with delinquent accounts and later received the aforementioned cancelled checks fromYankee Gas. Because Yankees Gas provided proof of payment to the tax collector's office, they werecredited their balance of $54,557.78. This is an example of how Guillet manipulated the Quality Datasoftware to accommodate the lapping scheme.

39) On 08/06/08, batch number 80-20 was opened and received transactions through 08/11/08. This batc(This ispage 9 of a 27


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ARRE$T WARRANT APFLICATIONJD-CR-64a Rev.3-11C.G.S. S 54-2aPr. Bk. Sec. 36-1. 36-2. 36-3

STATE OF CONNECTICUTSUFERIOR COURTwww.jud.ct.govFirst, Middle lnitial) GeographicalArea number 5Guillet, Karen

Affidavit - Continuedwas chosen because of a large check payment from Connecticut Light and Power in the amount of51.14,074.72. The check was deposited into the bank, but credit was not given by the Oxford TaxCollector's Office to Connecticut Light and Power for the payment. A late notice was sent to ConnecticutLight and Power requesting payment and they submitted proof (check #150178) that the payment hadbeen made. This batch was used as an example of how Guillet used the lapping scheme to significantlybalance the books, while also shorting the cash deposit. The batch report and transaction deposit sliptotals generated by Quality Data showed there was a total of $182,662.56 in tax credits in this batch. Ofthat amount, $19.98 was cash. However, Guillet's handwritten deposit slip stated there was only $17.08in cash, leaving a cash shortage of $2.90.

40) To substantiate the lapping scheme, Hliva and Kiley compared the cancelled checks supplied to them byNaugatuck Valley Savings and Loan to batch number 80-20. Per the transaction deposit slip the amountof checks that should have been deposited for batch 80-20 was $182,642.58. However, the bank depositslip showed the amount of checks being deposited as $182,645.48. This figure added to the fabricatedcash amount of $17.08 Guillet listed on the deposit slip allows the batch to equal the deposit of$182,662.56 and creates the illusion that the batch and deposit figures match. However, eighty-seven (87)taxpayers had payments credited to their tax account, but they did not make a payment on this day, sothere payment is not included in this batch. This manipulation of checks and cash is consistent withlapping.

41) On 08103/09, batch number 80-15 was created and closed on 08/04/09. This batch was chosen because itwas previously believed that Quaker Farms LLC had not paid their taxes. After inquiring with QuakerFarms, it was determined that they paid their taxes and produced a cancelled check (#1057) to thecomm-ttee. lJsing the bank validation codes on the back of the cancelled check, the committee was ableto determine with assistance from Naugatuck Valley Savings and Loan what batch and deposit the QuakerFarms check eame from. Hence batch number 80-15 was discovered. Two (2) deposits associated withthis batch were made on 08/04/09. The first deposit was for $223,063.02 and the second was for$2,894.16. The batch report and transaction deposit slip totals generated by Quality Data showed therewas a total of $225,961.18 in tax credits for this batch. Of that amount, $9,255.58 was cash. However, inGuillet's handwritten deposit slip stated there was only $858.54 in cash, leaving a cash shortage of$8,397.04.

42) To substantiate the lapping schemeo Hliva and Kiley compared the cancelled checks supplied to them byNaugatuck Valley Savings and Loan to batch number 80-15. Per the transaction deposit slip the amountof checks that should have been deposited for batch 80-15 was $216,705.60. However, the bank depositslip showed the amount of checks being deposited as $225,098.64. This figure added to the fabricatedcash amount of $358.54 Guillet listed on the deposit slip allows the batch to equal the deposit of$225,961.18 and creates the illusion that the batch and deposit figures match. There was difference of $4

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11/27

.ARRFST WARRANT APPLICATIONJD-CR-64a Rev.3-11C.G.S. S 54-2aPr. Bk. Sec, 36-1. 36-2. 36-3STATE OF CONNECTICUTSUPERIOR COURTwww.jud.ct.gov

Name (LastGuillet, Karen GeographicalArea number 5Affidavit - Continuedfrom the batch report to the bank deposits, possibly attributable to a mathematical error. However, eight(8) taxpayers had payments credited to their tax account, but they did not make a payment on this day, sotheir payment is not included in this batch. Furthermore, seven (7) taxpayers that'deposited checks didnot have their accounts credited in batch 80-15. This manipulation of checks and cash is consistent withlapping.43) On 081031A9, batch number 80-18 was created and received transactions through 0t/06/0g. This batchwas used as an example of how Guillet used the lapping scheme to significantly balance the books, whilealso shorting the cash deposit. Two (2) deposits associated with this batch were made on 0g/10/09. Thefirst deposit was for $130,315.47 and the second was for $66,636.24. The batch report and transactiondeposit slip totals generated by the Quality Data Software showed there was a {otal of $1gg,g51.71associated with this batch. Of that amount, $420.58 was cash. However, Guillefs handwritten depositslip stated there was only $51.71 in cash, leaving a cash shortage of $36g.57.44) To substantiate the lapping scheme, Hliva and Kiley compared the cancelled checks supplied to them byNaugatuck Valley Savings and Loan to batch number 80-18. Per the transaction aeposiislip the amountof checks that should have been deposited for batch 80-18 was $198,531.13. However, the bank depositslip showed the amount of checks being deposited as $196,900.00. This figure added to the fabricatedcash amount of $51.71 Guillet listed on the deposit slip allows the batch to Josely equal the deposit andcreates the illusion that the batch and deposit figures match. There was differettce of'$2,000.00 from thebatch report to the bank deposits, possibly attributable to a mathematical error. However, twelve (12)taxpayers had payments credited to their tax account, but they did not make a payment on this day, sotheir payment is not included in this batch. Furthermore, four i+l * payers that deposited checks did nothave their-aCCounts ciedited in batch 80-18. This manipulation of checks an1 cash is consistent withlapping.45) On 08113/09, batch number 80-22 was created and received transactions through 08117/09. This batchwas chosen because-while examining batch 80-21 Kiley noticed that taxpayeqMichael ploch paid histaxes in batch 80'22, but was credited in batch 80-21. After inquiring with pioch, it was determined thathe paid his taxes and produced a cancelled check (#8967) that clearly should have not corresponded tobatch 80'22. One (1) deposit associated with this batch was made on 08/17109. The batch report andtransaction deposit slip totals generated by Quality Data showed there was a total of $132,7g6.d7 rnlrlxcredits associated with this batch. Of that amoun! $577.75 was cash. However, Guillet's handwrittendeposit slip stated there was only $34.37 in cash, teaving a cash rftottugr oi Ss+g.gg. It should be notedthat there appears to be a minor addition mistake on G deposit slip. It should also be noted that theIlYe|["S valley savings and Loan counted taxpayer Danbi['s check t"r'$;71;.;t;r; il""".,r.Gill does his banking with Naugatuck Valley savinls and Loan. This method is internal and commonpractice for the bank.

(This it 11 ofa27page 71 ot a 27 pagel"/, 'nn'o'*ufu:l. 11/ KAJurat ")T*')-,Tu!n"fi:" me on (oarel o'n "o{*n"ff"^^W'y'W{ Notary Pubtic)r[try*: DEtel/-)r-r R eviewed (J u dg effidg e_fn a t n {n re q% Datetl >3 I


12/27

ARREST WARRANT APPLICATIONJD-CR-64a Rev.3-11C.G.S. S 54-2aPr. Bk. Sec. 36-1. 36-2. 36-3

STATE OF CONNECTICUTSUPERIOR COURTwww.jud.ct.govName (Lasl GeooraohicalArea'number 5Guillet, Karen

46) To substantiate the lapping scheme, Hliva and Kiley compared the cancelled checks supplied to them byNaugatuck Valley Savings and Loan to batch number 80-22. Per the transaction deposit slip the amountof checks that should have been deposited for batch 80-22 was $132,786.09. However, the bank depositslip showed an amount of checks being deposited as $732,751.70. This figure added to the fabricatedcash amount of $34.37 Guillet listed on the deposit slip allows the batch to equal the deposit of$132,786.07 and creates the illusion that the batch and deposit figures match. There was difference of$.02 cents from the batch report to the bank deposits, possibly attributable to a mathematical error.However, eight (8) taxpayers had payments credited to their tax account, but they did not make a paymenton this day, so their payment is not included in this batch. Furthermore, six (6) tax payers that depositedchecks did not have their accounts credited in batch 80-22. This manipulation of checks and cash isconsistent with lapping.

47) On 08120/09, batch number 80-25 was created and received transactions through 08124109. This batchwas chosen because two (2) large Bank of America checks (#450416 and#449783) were contained withinthe deposit. These checks were escrow payments from Bank of America mortgage customers. The two(2) deposits associated with this batch were made on 07129109 and08124109. The first deposit was for$577,975.32 and the second was for $45,389.18, respectively. The batch report and transaction depositslip totals generated by Quality Data showed there was a total of $623,366.80 in tax credits. Of thatamount, $1,407.89 was cash. However, Guillet's handwritten deposit slip stated there was only $7.98 incash, leaving a cash shortage of $1,399.91.

48) To substantiate the lapping scheme, Hliva and Kiley compared the cancelled checks supplied to them byNaugatuck Valley Savings and Loan to batch numbei 80-25. Per the transaction deposit slip the amountof checks that should have been deposited for batch 80-25 was $621,958.91. However, the validated bankdeposit slip showed an amount of checks "being deposited as 5623,356.52. This figure added to thefabricated cash amount of $7.98 Guillet listed on the deposit slip allows the batch to equal the deposit of$623,366.80 and creates the illusion that the batch and deposit figures match. There was difference of$2.30 cents from the batch report to the bank deposits, possibly a-ttributable to a mathematical error. Itshould be noted that the Naugatuck Valley Savings and Loan counted taxpayer Fairfield Consultantscheck (#0235) for $21.26 as cash because Fairfield Consultants do their banking with Naugatuck ValleySavings and Loan. However, thirty-five (35) taxpayers had payments credited to their tax account, butthey did not make a payment on this day, so their payment is not included in this batch. Furthermore, two(2) tax payers that deposited checks did not have their accounts credited in batch 80-25. Thismanipulation of checks and cash is consistentwith lapping.

49) On 08103/0g,batch number 80-20 was created. This batch was chosen because Tommy K's Plaza hadreceived a delinquent notice for their taxes. The owner of Tommy K's sent a cancelled check (#100574)


(This is page 12 of a 27 page Afndav:$jDate tu/,, sisned(enan,gr{" ffi 61,Jurat "fr!**f Y'{r.f:;" me on rDare) sitnea (t pls eE e/f ^ f"p':p* Y/ ff* o r, o0,,Ktty*' Datell-13-l Reviewed (Jufl{eQUdge Tial Referee)lW Date Irf lzEl


13/27

ARREST WARR,ANT APPLICATIONJD-CR-64a Rev 3-11C.G.S. S 54-2aPr. Bk. Sec.36-1, 36-2,36-3ameGuillet, Karen

STATE OF CONNECTICUTSUPERIOR COURTwww.jud.ct.govGeographicalArea number 5Affidavit - Gontinuedto the tax collector's office proving the payment of said taxes. Hliva asked Naugatuck Valley Savings and

Loan to provide him with all the deposits for 08112109, the day the deposits associated with this batchwere made. It was discovered there were two (2) deposits made on 08112109, one (1) from the abovementioned batch and one (1) from batch 81-16. The batch report and transaction deposit slip totalsgenerated by Quality Data showed there was a total of $212,729.30 in tax credits from these two (2)batches, $I1L,692.21 from batch 80-20 and $101,037.09 from batch 81-16. All associated paperworkfrom batch 81-16 corresponded with the bank deposit. The problem lies within batch 80-20. Of the$1I1,692.21 deposit, $483.02 was cash. However, Guillet's handwritten deposit slip stated there was only$49.40 in cash, leaving a cash shortage of $433.62.50) To substantiate the lapping schemeo Hliva and Kiley compared the cancelled checks supplied to them byNaugatuck Valley Savings and Loan to batch number 80-20 and 81-16. Per the transaction deposit slip

the amount of checks that should have been deposited for batch 80-20 was $111,209.19. However, thebank deposit slip showed an amount of checks being deposited as $105,779.72. At additional separatedeposit from a single check in the amount of $5,863.09 was made to balance out the batch report figures.This total check figure ($111,642.81) added to the fabricated cash amount of $49.40 handwritten byGuillet listed on the deposit slip allows the batch to equal the deposit of $111,692.21 and creates theillusion that the batch and deposit figures match. However, twelve (I2) taxpayers had payments creditedto their tax account, but they did not make a payment on this day, so their payment is not included in thisbatch. Furthermore, five (5) tax payers that deposited checks did not have their accounts credited in batch80-20. This in another example of how Scinto's batch (81-16) created the same day and deposited on thesame day was not manipulated and the figures corresponded with one another. However Guillet's batch(80-20) was manipulated consistent with the other examples. This manipulation of checks and cash isconsistent with lapping.

51) To prove there were no issues with Quality Data's software and to show Guillet was solely.:accountablefor the tax office improprieties, Hliva and Kiley examined batch number 81-13 that was created on08/03/11 and received transactions'tlrough 08/04/11. This batch was prepared by Sharon,scinto on thesame day the previously outlined batch numbers 80-15 and 80-20 were created by Guillet. Three (3)deposits associated Scinto's batch were made on 08104109. The first deposit was for $3,260.08, thesecond was for $6,930.34 and the third for $322,155.23. The batch report and transaction deposit sliptotals generated by Quality Data showed there was a total of $332,345.60 in tax credig on 08/04/09. Ofthat amount $6,180.45 was cash. The total amount of checks in this batch was $326,165.20. There was a$.05 cent discrepancy between the deposit and the batch. This was clearly attributable to a typographicalerror in check #567 fuom Julia Hamilton. The deposit ticket listed Hamilton's check as $330.92, and thecheck is actually for $330.97. All the checks supplied from Naugatuck Valley Savings and Loan weredeposited in Scinto's batch and all the checks and cash *.r. u..ounted for. The above example helpsprove that both Quality Data's software works and Guillet was solely to blame for the lapping scheme.

(This is page 13 sf a 27


14/27

ARREST WARRANT APPLICATIONJD-CR-64a Rev. 3-'11C.G.S. S 54-2aPr. Bk. Sec. 36-1, 36-2. 36-3

STATE OF CONNECTICUTSUPERIOR COURTwww.jud.ct.gov

Affidavit - Continued52) Due to the size and significance of the paperwork associated with the check lapping scheme, thedocuments outlined above were seized and secured as evidence. The supporting documentation to thelapping scheme was assigned Exhibit #9.53) On 09/29111, Finance Director Jim Hliva provided me with a spreadsheet listing the taxpayer accountsthat were once thought to be delinquent. Due to the apparent delinquent status, the Oxford TaxCollector's Office issued delinquent notices to the taxpayers. Since issuing the delinquent notices, thetaxpayers have provided the tax collector's office with $682,582.83 in cancelled checks to prove theirtaxes have been paid. As outlined in the lapping scheme report, the biggest taxpayers like Yankee Gas

and Connecticut Light and Power were among the alleged delinquent taxpayers.54) Even though these accounts were shown to be delinquent, Guillet never mentioned any large outstandingdebts to the Board of Finance. Also Town Attorney Teodosio asked Guillet to give him a listing of allmajor tax accounts that had balances due. Teodosio was going to use this information and legal means tocollect the outstanding accounts. Guillet never gave any information of delinquent accounts to Teodosio.By committing the lapping scheme Guillet was able to manipulate the accounts receivable account. Thelapping scheme would create the illusion that the tax office records were verified as accurate and allowed

the tax office to pass their annual audit. Hence the reason there never seemed to be a problem with the taxoffice records throughout the years.55) After breaking down the lapping scheme Guillet was using to embezzle funds from the tax collector'soffice the finance department was tasked with determining the trail of cash from the taxpayer through the

tax office and ultimately to Guillet. Finance Director Jim Hliva requested a listing of posted tax paymentsfrom Quality Data where cash was the method of payment. Quality Data supplied the calendar years of2008 and 2009. 2007 was not supplied because it was previously determined-by Hliva and his ,Lfftttutthere was not an ample sample size of documents remaining in the tax collector's office to compile anadequate sampling size. Furthermore, the+month of December 2009 was not used because December2009 was the month Guillet's scheme was uncovered and generally a very low tax collecting monthanyway.

56) The files from Quality Data were sorted by batch number and then by date. The purpose of both sorts isthat batch numbers are reused in different fiscal years. The first two (2) numbers in the batch numberrepresent the computer operator. Number 80 was used by Tax Collector Karen Guillet and 81 was usedby Assistant Tax Collector Sharon Scinto. The next two (2) numbers were conseoutive numbers whichidentified the batch. The numbers begin from I at the beginning of each fiscal year.

57) Hliva then took random reports from the Office of the Tax Collector to veriff the cash posting,(This is page 14 of a 27

Caurt, Notary Public)


15/27

ARRH$T WARMNT APPLICATIONJD-CR-64a Rev.3-11C.G.S. S 54-2aPr. Bk. Sec.36-1. 36-2.36-3

First, Middle lniUal)Guillet, Karen

STATE OF CONNECTICUTSUPERIOR COURTwww.jud.ct.govGeographicalArea numbor 5

coffesponding deposit tickets and validated deposit tickets. The search was random, because there wasnot enough documentation available to make complete records for every batch. Once a complete packagewas found the following was looked at to ascertain if there was a cash shortage: The amount of cash perthe computer reports (Quality Data), the amount of cash as hand written on the original deposit ticket, theamount of cash as validated by the bank and that the total amount of the deposit as validated by the bankwas in agreement to the computer reports.

58) It was found within the first batch reviewed that the validated cash by Naugatuck Valley Savings andLoan was greater than the cash deposited per the tax collector and the computer reports. This promptedHliva to inquire with Naugatuck Valley Savings and Loan as to how this could be. Naugatuck ValleySavings and Loan stated that the cash number on the validated deposit ticket is comprised of two (2)items. The first being the actual cash deposited and the second being any checks that were wriffen onNaugatuck Valley Savings and Loan checks that were included in the deposit. The bank considers thesechecks as "honest checkso' because they know the funds are in the bank and they are treated the same ascash. This created a problem because the actual cash could not be verified. Naugatuck Valley Savingsand Loan was then asked to give a breakdown of the actual cash and the checks recorded as cash (honestchecks). After the checks were received by Hliva, he compiled a spreadsheet containing examples ofbatches with the cash paying taxpayers. The different batches contained within the spreadsheet outlinesthe flow of cash in each batch depicted. The spreadsheets were sorted by cash shortage, by batch numberand by date and were made part of the case file. The spreadsheets were labeled as Tables 6a,6b, and 6c,respectively.

59) A total of one-hundred (100) batches were reviewed, giving an accurate depiction of all the batches. Italso shows a signihcant trend of the overall casFskimming scheme being carried out by Guillet. PerQuality Data, the total cash collections from 01/01/08 to 11130109 totaled $655,099.84. The one-hundredliOO; Latches that were analyzed by Hliva had a total cash amount of $339,421.26. This means the one-hundred (100) batch sample size covered $51.8% of all of the cash collected by the tax collector in thetwenty-three (23) month period mentioned above.

60) The one-hundred (100) batches show there should have been cash deposits of $339,42I.26. However, the' handwritten deposit tickets show only $95,024.17 was to have been deposited by Guillet. The actual cashgiven to the bank and validated by the bank was $95,519.08. This left the Town of Oxford with a cashshortage of $243,902.18 on the batches verified. The difference betwoen the tax collector amount and thevalidated amount ($494.91) could possibly be athibuted to mathematical error over the one-hundred (100)batches.

61) Of the one-hundred (100) batches examined, only sixteen (16) batches showed all the documents to tie inexactly. Of those sixteen (16) batches, fifteen (15) were prepared by Scinto. The total cash amount of


(This is page 15 of a 27 page Affidavit.) {nADate l^3/' Sisned (AfiianD n t-f Jrtl- U F.nI SLbscribed?ftdsworn D before me on fAaF)Jurat )/ /ttlvtl',, $i g ned (Jude;/c/o.(K, yW, yg:"U1 o*trffi'on'* ' l"ii-=r- ReueweQ ( u dge/J u{ga Ti al Rafere e )I@ uate tIt l>v1


16/27

ARREST WARRANT APPLICATIONJD-CR-64a Rev.3-11c.G.s. s 54-2aPr. Bk. Sec. 36-1. 36-?. 36-3STATE OF CONNECTICUTSUPERIOR COURTwww.jud.ct.gov

Guillet, Karen GeographicalArea number 5Affidavit - Continuedthesefifteen(15)batcheswas$5l,33l.g5incashwithanaveragecashperdepositof$3,422.13. There

was only one (1) deposit of Guillet's that tied in exactly and the total cash deposited was $46.27 (batch80-61). There were two (2) addition batches prepared by Guillet that had very small differences and wereprobably the result of a mathematical error. Batch 80-18 was over .02 cents, but the total deposit of cashonly totaled $51.71.. Batch 80-20 was short $1.89, but the total deposit of cash only totaled $18.09.

62) As stated earlier, only 2008 and 2009 were used to compile the one-hundred (100) examples. This wasbecause only a small quantity of the records could be found from 2007. However in the month of January2007 eight (8) complete batches were found and the total missing cash was $35,303.08 Also in the monthof July two (2) complete batches were found and the missing cash was $7,776.73 . The reason why thesemonths were chosen to sample from was because January and July are generally the two (2) highest taxmonths in the fiscal year. A separate worksheet was generated and outlines these two (2) months.

63) On 09127111, Finance Director Jim Hliva provided me with copies of leffers sent to the Oxford taxpayersthat paid cash for their Fiscal Year 2008 taxes. The letter asked the taxpayer to provide proof of theircash payment. This was done to aid in the cash skimming portion of the investigation. The town mailedapproximately eight-hundred (800) letters. By 09127111, the town had received one-hundred (124)responses in which the taxpayer provided the correct information (i.e. receipt) that can be used tosubstantiate the payment. One-hundred thirty four (134) letters were returned by the post offtce. Twenty-six (26) letters were returned with incorrect information due to a variety of reasons such as wrong dateson the receipt or the taxpayer paid in check, not cash as indicated by the tax records. Five-hundredsixteen (516) people did not respond to the request.

64) The rate of retum on the letters from the taxpayers is 18.620/o. These letters verified $89,866.65 in cashpayments to the Oxford Tax Collector's Office. If there was a I00% return of all the letters, the projectedlclss for Fiscal Year 2008 would have been approximately $418,670.88, based off the 15.62% retum rate.

65)Sue to the size and significance of the paperwork associated with the cash skimming scheme, thedocuments outlined above were seized and secured as evidence. The supporting documentation to thelapping scheme was assigned Exhibit #10.

66) Through the course of the investigation State Police Detectives spoke with many individuals with, information to offer regarding Guillet, her lavish spending habits and the suspected larceny. In order togain information regarding the embezzlement within Oxford Town Hall several town employees wereinterviewed.

67) On 07/l2l|l, Detective Van Ness #1431 and I interviewed Joyce Eades in a meeting room located atOxford Town Hall. During the interview Eades stated the following in part; Eades stated she has beena.(Ihls is page 16 of a 27 Page


17/27

ARREST WARRANT APFLICATIONJD-CR-64a Rev.3-11C.G.S. S 54-24Pr. Bk. Sec. 36-1, 36-2, 36-3

STATE OF CONNECTICUT$UPERIOR COURTwww.jud.ct.govName (Lasl GeooraohicalArea-number 5Guillet, KarenAffidavit - Continuedworking at Oxford Town Hall since 1986. She was initially hired as a part time worker in the tax

collector's office. In 1987 she started working in the assessor's office and has remained in that positionsince. Eades stated she has known Karen Guillet since 1974, when Guillet had a day care business inAnsonia. Guillet provided child care for Eades' son. Eades stated she and Guillet became very goodfriends.

68) Eades stated the tax collector's office and the assessor's office share the vault between the rooms in townhall. Eades further stated access to the vault was limited. Eades stated she would sometimes use thetlpewriter in the vault to type new homeowner cards, but she has not used the typewriter in years.69) A number of years ago, while working in the assessor's office an employee from Quality Data informedEades that the property assessment of 2 Douglas Drive (Guillet's residence) had been changed. Eades

further stated it was strange that Guillet's assessment would change for no apparent reason. Eades statedshe did not know who made the change in the system and did not know enough about the system todetermine who made the changes. Eades also stated Guillet always said Quality Data's software could notaccommodate the sewer assessors or the aircraft program in the system. Furthermore, Guillet kept tellingthe assessor's office that the assessor's office and the tax collector's offrce could not be linked to eachother with Quality Data's software. Guillet's beliefs regarding the computer software were found to befalse by the assessor's office. Eades went on to state no one in town hall really had any control overGuillet. Eades stated Guillet had "carte blanche at town hall for years." She also stated there was neveranyone to go to over the years in town hall. Aside from First Selectnan Drayton-Rogers, if things werementioned to a first selectman they would say "okay" but nothing was ever done. Eades stated that overthe years Guillet always told everyone what they wanted to hear referring to the computer system, thetown auililors, and her fellow employees. Therefore, there were never any issues.

70) Eades stated the worst day in town hall was- I llTg/09. She stated on 11/10/09, Guillet was off from workand Sharon Scinto was alone in the tax collector's office. Because Guillet was off, Scinto asked Eades toattest her,bank deposit figures. Scinto had a deposit consisting of mostly checks ($27,695.46) and$3,093.42 in oash. On lll19l09, Scinto discovered that her deposit ticket had been altered and brought itto the attention of Eades. The deposit ticket revealed a much lesser amount of cash.

71) Eades stated Guillet always carried a lot of cash. She knew this because she would sometimes ask Guilletto borrow money and she could see how much cash Guillet had in her purse when she would open it. Shefurther stated Guillet was always wearing expensive clothing and jewelry. Guillet athibuted her wealth toinherited money from her aunt and a trust fund from her parents. Eades ttrought Guillet's spending habitsand material possessions were suspicious. During a holiday party, Eades asked Guillet's sister (Janet)about the alleged inherited jewelry that Guillet wore and the trust fund left to them by their parents. Janestated to Eades that their aunt did not leave jewelry to Karen. In response to the trust fund Janet stated to

(Ihls is page 17 of a 27,


18/27

ARREST WARRANT APPLICATIONJD-CR-64a Rev.3-11C.G.S. S 54-2aPr. Bk. Sec. 36-1, 36-2, 36-3STATE OF CONNECTICUTSUPERIOR COURTwww.jud.ct"gov

Name {Last, GeooraohicalArea'number 5Guillet, KarenAffidavit - Continued

Eades with a funny look on her face "Like what are you talking about?" Janet went on to state there wasno such trust fund for any of the kids.

72)Eades stated that in October 2010 Guillet asked Eades'former husband (Kenneth) if she could borrow$5,000 from him. Her husband lent Guillet the money. Guillet never told Kenneth Eades what the moneywas for and has yet to pay him back. However, Guillet told him that her sons needed money to pay theirpersonal properly taxes in Beacon Falls, but is not sure that is actually what Guillet used the money for.

73) Eades stated while Guillet was employed by the Town of Oxford there were always credit card companiescalling to collect payments from Guillet. She fuither stated the calls from the uedit card companiesincreased after Guillet resigned.

74) Eades recalled several incidents through the years when checks and cash were found in unusual placesaround the tax collector's office. Eades further stated it didn't make sense that these checks were notdeposited.

75) Shortly before Guillet resigned from Oxford Town Hall, Eades stated Guillet stopped leaving the officefor lunch and was spending a great deal of time in her office. Eades stated Guillet cleaned out her deskand was throwing a lot of things in the garbage and tearing up papers. Eades stated this behavior was outof the ordinary.

76) On 07/20111, Detective Van Ness and I interviewed Alice Hardej in a meeting room at Oxford TownHall. Hardej works in Building Department at Oxford Town Hall. During the interview Hardej stated thefollowing in part; Hardej told us about an incident that occurred in December 2009 during a bus trip toNew York City. Hardej stated Guillet asked Hardej and her daughter to look for knee boots for her inBloomingdale's, to purchase them and Guillet would pay her back. Hardej and her daughter found two (2)different pairs of boots costing $600 and $1,800 in Bloomingdale's. Hardej called Guillet's cell phone toinform her of the boots they had located in Bloomingdale's. Hardej was'irnable to speak to Guillet, so sheleft her a message. After returning to Connecticut, Hardej stated she noticed she had a missed call andvoice mail from Guillet asking her to purchase the $1,800 boots for her. Hardej brought this incident toour attention because she thought it was strange for someone to spend that much money on a pair ofboots.

l7)Hafiejalso told us about the times she would filI in as a floater in the tax collector's office between 1993and 1998. Hardej stated she noticed unpaid balances in the tax collector's computer system. Hardejwould bring the unpaid balances to Guillet's attention, at which time Guillet told her to ignore the unpaidbalance and attributed it to a computer software problem. Hardej stated she did not make entries into theQuality Data software, nor did she make deposits, only Guill.et would.

(This is 18 af a 27 page

Court, Notaty Public)_BlrJ_


19/27

ARREST WARRANT APPLICATIONJD-CR-64a Rev.3-11C.G.S. S 54-2aPr. Bk. $ec.36-1, 36-2. 36-3

STATE OF CONNECTICUT$UPERIOR COURT!v\ /w.jud.ct.gov

{Last, FisL GeooraohicalArea'number 5Guillet, Karen

78) Hardej stated she occasionally would use the typewriter in the tax collector's office to type names andaddress on envelopes.79) On 07lLzl|l, Detective Van Ness and I interviewed Ann Cummings in a meeting room at Oxford TownHall. Cummings works in the Finance Department at Oxford Town Hall. During the interviewCummings stated the following in part; Cummings stated she has been working in Oxford Town Hall

since 1987 as an assistant bookkeeper, then eventually bookkeeper for the town. Cummings stated fromthe first day she worked in Oxford Town Hall she thought Guillet was a "phoney." She further stated shedid not normally deal with the tax collector's office, but would sometimes go into the office for attendancepurposes and to use the typewriter. She stated the typewriter was used for typing out checks, forms orenvelopes.

80) Cummings stated Guillet lives a lifestyte quite different from anyone else who worked in town hall. Shefurther stated Guillet was always receiving packages at town hall from high end department stores. Shealso stated that Guillet was very generous when giving gifts to other employees. She would buy otheremployees clothes, toys for their children and sometimes jewelry. When it was Guillet's turn to ordertunctr for a special occasion at town hall she would have the lunch catered, rather than prepare somethinghomemade as the other employees normally do. Cummings attributed these acts of kindness and Guillet'slavish spending to the income generated from her husband's construction company.

81) Cummings also recalled several lies Guillet has told over the years, such as her sons being deployed toIraq, vacations abroad that she never had any pictures of; nor did she take the time-off from work to go onsuch vacations, lying about her age and dress size, etc.

82) Cummings stated Guillet rarely took a day off from work and from 2000 to 2009 qhe has lost close to 100days of leave that she was entitled to. +

83) Cummings reoalled an incident in December 2009 when Scinto approached Cummings crYing, but wasreluctant to tell her what was going on. When Guillet was escorted out of town hall a month later,Cummings said only then she rcalized the cause of Scinto's sadness.

84) During the course of the internal investigation launched by the Town of Oxford and the criminainvestigation by the State Police, Cummings was assigned to sort through the tax collector's documents sothey can be organized and made part of the investigation. Cummings stated the tax collector's office andthe documents contained within were in total disarray. She further stated it took them a couple months toget everything in order.


to before me on (Date)

(Ihts is page I I of a 27


20/27

ARREST WARRANT APPLICA.TION,lD-CR-64a Rev. 3-11C.G.S. $ 54-2aPr. Bk. Sec.36-1,35-2, 36-3Name /Last First, MiddleGuillet, Karen

STATE OF CONNECTICUTSUPERIOR COURTwww.jud.ct.govGeographicalArea number b

85) On 07120111, Detective Van Ness and I interviewed Eve Detzer at Oxford Town Hall. During theinterview, De1zelr stated in part the following: Detzer stated she began working as a part time finance clerksometime around May, 2009. Detzer stated that other than distributing paychecks, she had very littlecontact with Guillet. Detzer stated that after Karen left, she was asked to fill in at times in the taxcollector's office, answering phones and assisting residents with bill paying. De%er stated she believedshe was asked to fill in on two (2) separate days for a few hours a day. Delzer also stated that prior toGuillet's departure she had utilized the tlpewriter in Guillet's office to type checks on at least one (1)occasion.

86) Detzer stated she had been tasked by Finance Director Jim Hliva with matching up documents taken fromthe tax collector's offrrce, such as deposit slips, receipt rolls, bank receipts and batch reports. Detzer statedthat the documents were in various boxes, bags and containers that may have been partially labeled bymonths and years, but that further inspection of the contents showed that the documents did not match thelabels. Detzer stated that all documents were systematically separated and put in order, but many of thedocuments were missing. Detzer stated that in the process of separating documents she discovered thatthe totals of batch reports, deposit slips, tapes and bank receipts were in balance, but that after carefulreview of the reports many made no sense. Detzer explained that the total cash listed on the deposit slipsdid not equal the total cash on the batch reports and tapes, despite the fact that the grand totals were inbalance. Detzer stated upon further inspection, checks, which had been held from previous days, wererecorded in the deposit slip "checks total" in place of cash that had not been deposited, in order to makeup the difference. Detzer stated she also noticed that many of the bank deposit receipts had the validationdata on the back typed by a typewriter, rather than printed by the bank's machines, indicating that cashdeposits had been processed, when in fact they had not. De%er stated there were also checks individuallylisted on deposit slips which haifiot been received in batdh report for the same day, leadi@her to believethat they had been previously submitted by tax payers but held by Guillet until thery were needed byGuillet to replace cash figures and bring the"days "total deposit' in balance with the reports.

87) On 07112/11, Detective Van Ness and I interviewed Oxford Assistant Assessor TeresfGeremski in ameeting room at Oxford Town Hall. During the interview, Geremski stated the following in part;Geremski stated she has been working in the Oxford Assessor's Office since 2006. She further stated theassessor's office shares a vault with the tax collector's office. Geremski stated Guillet's office was veryunorganized and very much in disanay.

88) Geremski stated when she first started working at town hall she would enter Certificates of Correction,which changes the assessed value of a properly, into her computer system in the assessor's office. Shewould then give the Certificate of Correction to Guillet to be changed in the tax oollector's system.Geremski found this practice strange and knew that there were statutes against tax collectors changing theassessed value of a property. After approximately six (6) months of working at town hall, Geremski




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ARREST WARRANT APPLICATIONJD-CR-64a Rev. 3-'11C.G.S. $ 54-2aPr. Bk. Sec. 36-1, 36-2. 36-3STATE OF CONNECTICUTSUPERIOR COURTwww.jud.cl.gov

(LaEt, Firct,Guillet, Karen GeographicalArea number 5Affidavit - Continuedquestioned Guillet's practice. Geremski learned that Guillet had the software company (euality Data)turn off the bridge that automatically changes the assessed value of a property in the tax cotieitor,s systemimmediately after rhe value is changed in the assessor's ofhce. when c-.r.-Ji uf;;;; Griilet withthis Guillet's response to Geremski's was that she never trusted anyone to make the proper "ha.rge, in theassessor's office, so she requested the bridge be shut off.89) Geremski stated Scinto approached her on the day she discovered the improprieties with the deposit slipsbelieved to be fabricated by Guillet. she further rtut"a the deposit slip that'Guillet had deposited did notinclude the cash Scinto had previously counted and closed with. Geremski overheard Scinto questioningGuillet about the deposit at which time Guillet stated she was going to the bank to ngure out whathappened' Guillet left and returned approximately five (5) minutes laier and stated she wluld go to thebank the following day. Guillet never mentioned ihe incident to Scinto again, but Geremsti urgio her toreport the incident to the front office.90) on 07ll2ll1, Detective Van Ness and I also interviewed Geremski's boss, Town Assessor Eva Lintzner ina meeting room at oxford Town Hall. Lintzner stated she began working in the assessor's omr" rin".2004' Lintzner further stated Guillet was well respected in her position u, [" oxford Tax Collector whenshe began working at town hall and__was also a very caring, concerned and productive member of theoxford community' she stated Guillet was always very generous to some town employees babuyinggifts and catered lunches to celebrate special o""uriorrr. She further stated Guillet seemed to live a moreprivileged life compared to the other employees at town hall. Lintzner stated Guillet always had lovelyclothes, drove new Jaguars and had money to spend. Lintzner added that Guillet stated she had a trustfund from her father.9l) LinZner stated Guillet complained to the Board of Finance and the Board of Selectman about theassessor's office making mistakes with their adjustrnents and creating lots of work for her. As Lintznerexplained the assessor's office was doing their work correctly ano c:uittet *"r ;;;r[lr^i" ui"-i due toher poor record keeping. Lintzner statedronce her assistant (Geremski) was hired the assessor,s office waslinked to the tax collector's office (Quality Data) and Guilletis complaining subsided.

92) Lintner gave a specific example of Guillet's questionable practices when she recalled a time when theTown of oxford was sued by Timberlake Gulf Partrrers in regard to the assessment of their property.During negotiations the town attorney asked Lin,?ner to check and see if the taxes had been paid onTimberlake Gulf Partner's property. Lintzner found that the computer system stated their taxes had notbeen paid and there was inJerest owed to the town. when Lintzrir quesiioned Guillet about TimberlakeGulf Parhrer's taxes not being paid Guillet staled they paid their taxes, but Guillet had not entered thepayment into the system yet. Lintzner stated the situati,on was uncomfortabb 6;;dh; il;;j:;k ""his specific piece of property . Lintzner ended her statement by saying she feels betrayed and hurt by21 ofa27


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ARREST WARRANT APPLICATIONJD-CR-64a Rev,3-11C.G.S. S 54-2aPr. Bk. Sec. 36-'1. 36-2, 36-3

ameGuillet, Karen

STATE OF CONNECTICUTSUPERIOR COURTwww.jud.ct.govGeooraDhilArea'number 5

Affidavit - ContinuedGuillefs actions. She further stated "'We were a trusting community and that has been shattered."93) On IllI5lI1, Sergeant Kline #142 and I interviewed Crudele in his office located at Quality DataServices, Inc. Quality Data is the software company that provides tax collector and town assessorcomputer services to over 130 towns in the Connecticut, including the Town of Oxford. Crudele is thepresident of Quality Data Services. During the interview Crudele stated he has been providing hiscompany's services to the Town of Oxford for over twenty (20) years. Crudele stated he became aware of

the issues involving Karen Guillet at Oxford Town Hall on 07105109. He further stated on this date hereceived a call from Guillet stating her elderly tax accounts were not balancing and asked if Crudelewould take a look at the problem. Crudele went to Oxfrod Town Hall and spoke with Guillet. He told herduring that time that the elderly accounts could not cause an imbalance. Furthermore, the software wouldnot allow an imbalance. At this time Guittet told Crudele she had been drafting all of the Certihcate ofCorrections (C of Cs). Crudele stated that this practice was improper and illegal. He further statedassessment changes should only be made by the assessor's office and the tax collector should only bemaking money changes (i.e. elderly credits, donations, et cetera). Crudele then told the assessor's officethat the current practice was unacceptable and giving Guillet control over the C of Cs allowed her to dowhatever she wanted with the information within the database. The assessor's office stated that this is theway it has always been, regarding Guillet handling the C of Cs. It was Crudele's understanding that thispractice ceased on this day. Crudele's statements are consistent with the statements provided by TownAssessor Eva Lintzner, Assisstant Assessor Teresa Geremski, and Assessor's clerk Joyce Eades in regardsto Guillefs control of the C of Cs.

94) Crudele remembers times in the past when representatives from the Town of Oxford called his company. " ' asking why Oxford's hx collections were so low. Crudele stated he considers anything below 96Yo verybad. He further stated sometime between 1992 and l994he believed the tax collection rate to be around:i: 92/93%. Crudele stated one of his employees oalled Guillet and asked her for a possible reason why thecollection rate was so low. Guillet's response was that the reason why the collection rate was so low was.E.. because an escrow check from a bank was mistakenly deposited by the finance office, bypassing hetoffice and not properly crediting the town's tax account

95) Regarding the bridge in the software between the assessor's office and the tax collector's office Crudelestated the bridge could not be turned offbecause it is one (1) database.

96) On lll02ll1, Detective Mudry and I interviewed Judith Melko. On 1ll10/11, Detective Mudry,Detective Van Ness and Sergeant Kline completed a twelve (12) page written statement with Melko.Melko is Guillet's former dog sitter and supplied detectives with intimate knowledge of Guillet's personalexpenses as well as the cash and financial documents being secreted at her home in Oxford.



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ARREST WARRANT AFPLICATIONJD-CR-64a Rev. 3-'11C.G.S. $ 54-2aPr. Bk. Sec. 36-1, 36-2, 36-3STATE OF CONNECTICUTSUPERIOR COURTwww.jud.ct.gov

(Lest, F rst. Middle lnitial) GeographicalArea number 5uillet, KarenAffidavit - Continued97) Melko stated she met Guillet when she began working as a part time receptionist at Oxford Town Hall inthe 1990's. Melko later left Oxford Town Hall and was hired by Guillet to watch her dog when herhusband and she would go out for the night. Eventually Guillet hired Melko to work for her everyday andpaid her $100 cash/day. In addition to watching her dog Melko stated she was tasked with completingother various responsibilities such as working around the house, running errands, making bank deposits,picking up and dropping off dry cleaning and shopping for Guillet. Melko further stated Guillet alsohired a cleaning lady, several gardeners, a second dog walker, a baker, and a florist that delivered freshflowers to Guillefs home every Friday. Melko stated Guillet's husband did not know what Guillet waspaying the workers because she only paid them when her husband was not around and always in cash.

98) Aside from the hired help around the house, Melko stated Guillet spent unbelievable amounts of moneyon clothes, beauty treatments, vacations, jewelry, home d6cor, and landscaping around the house.99) Melko stated Guillet would have her make cash deposits to Bank of America nearly every week. Melkofurther stated the deposit envelopes were always sealed when she took them to the bank, but were openedand counted in her presence by the bank teller. Melko stated the deposits were always cash, mostlycontaining $100 denominations. She further stated the usual deposit amount was anywhere between$2,000 to $3,000 weekly. Guillet would tell Melko that the money was from her father or husband.Guillet instructed Melko to put the receipts from the deposits in the "QXR' room. '(QlKIt" was the codeword for the laundry room in Guillet's house. According to Melko, the laundry room was Guillefs hidingplace for financial documents. In addition to the receipts being put into the "QXR" room, Melko statedshe observed Oxford town resident's tax bills in the room as well. Melko further stated she once observeda dresser drawer in Guillet's bedroom full of cash containing all different denominations of cash. Melko

-tated there had tote thousands of dollars stashsd in thedresser.l00LMelko went on to state that Guillet's husband was not giving her (Guillet) the cash she was spending.Melko went on to give several examples of times when Guillet would attribute a costly purchase such as a,*dinner to the money her husband gave her. Melko stated she would then ask or thank Guillefs husbandfor the dinner and Guillet's husband would respond by sayng he did not give her money for anything.101) Through the course of the investigation State Police Detectives learned that Guillet used her Bank ofAmerica checking account for her payroll direct deposit. A search and seizure warrant was obtained forthis account. Using the figures depicted on the deposit slips for the years of 2007,2008, 2009 they showsignificant cash deposits totaling $470,850.00. The total deposit figure, which includes checks and other

credits, totaled $555,023.40. In addition to the significant cash deposits made to Guillet's Bank ofAmerica checking account were electronic payments made to Amirican Express from 12112/06 to02/08110 in excess of $199,000.00. All the payments were in the name of Karen M. Guillet. Bank ofAmerica also informed me that Guillet holds a credit card through Bank of America, but the account isflhis is page 23 of a 27 page


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ARREST WARRANT APPLICATIONJD-CR-64a Rev.3-11c.G.s. $ 54-2aPr- Bk. Sec. 36-1. 36-2. 36-3

First, MiddleGuillet, Karen

STATE OF CONNECTICUTSUPERIOR COURTwww.jud.ct.gov

GeographicalArea number 5Affidavit - Continued

maintained by FIA Card Services, N.A.102) Two (2) additional search and seizure waffants were applied for and obtained to retrieve records for

Guillet's credit card maintained by FIA Card Services and American Express.103) On 05109/11, the results of the search and seizure warrant requesting Guillet's credit card statementsthrough FIA Card Services for the yeus )007 through 2010 were delivered via UPS to Troop A. A

spreadsheet was compiled showing Guillet's spending and payment habits over the course of theaforementioned time frame. The spreadsheet was labeled as Table #4 and incorporated into the case file.

104) The total charges and purchases for this time frame by Karen Guillet were $10,807.90. The total amountof payments Guillet made during this period was $23,942.98. None of the purchases made on the FIACredit Card appeared to be frivolous or unnecessary.

105) On 08/30/11, the results of the search and seizure warrant requesting Guillefs American Expressstatements were delivered via UPS to Troop A. The statements covered a period of time that includedJanuary 2007 through July 2010. A spreadsheet was compiled showing Guillefs spending and paymenthabits over the course of the aforementioned time frame. The spreadsheet was labeled as Table #3 andincorporated into the case file. The statement showed AMEX account number 3713-806230-91003 to bein the name of Nil Guillet. An additional account in the name of Karen Guillet is also attached to NilGuillet's account. Karen Guillet's account number ends in gl02g. This differentiation in card numbersallows independent tracking of the separate accounts, even though the expenditures appear on the samestatement.

106) The statement also shows accountnumbers ending in22005 and220I3linkedto Nil Guillefs account.However, there were no names or expenditures linked to these accounts.

107) During the aforementioned time frame, Karen Guillet was the- only person charging purchases to theAMEX card. The only charges Nil Guillet incurred over this time period were administrative chargessuch as yearly fees and late fees, most likely because he was the main account holder.

108) The total charges and purchases for the time period of 2007 to 2010 by Karen Guillet was $108,7 7t.07.The total amount of payments Guillet made during this period was $113,915.95.

109) The statements also depict how Guillet's payments to AMEX stopped once she resigned from the Town ofOxford. The only charges incurred since her departure from Oxford are late penalties for non-payment.110) Guillet's spending over this time period was mostly at posh clothing and department stores, hotels,


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ARREST WARRANT APPLICATIONJD-CR'64a Rev.3-11C.G.S. $ 54-2aPr. Bk. Sec. 36-'1, 36-2, 36-3

Firsf.Guillet, Karen

STATE OF CONNECTICUTSUPERIOR GOURTwww.jud.ct.govGeooraDhilArea-number 5

casinos, spas, and salons. For example, during a period of nine (9) months in 2007, Guillet spent99,437.35 at a salon and spa in Southbury. In March 2007, Guillet made three (3) separate purchasestotaling $5,812.28 at a posh clothing store in Westport. She also made a single purchase at the same storein June 2009 for $3,537.83. During a one (1) night stay at the Foxwoods Resort and Casino in September2009, Guillet spent $1,980.92 on lodging, jewelry and dining. During what appears to be a one (1) nightstay at a luxury hotel in Keene, New Hampshire Guillet spent $2,382.76. Guillet also spent tens ofthousands of dollars at high end stores such as Swarovski Crystal, Neiman Marcus, Saks Fifth Avenue,Lord & Taylor, Williams Sonoma, et cetera. These purchases are exclusive to her AMEX card.

111) On 08122111, I requested the Connecticut tax records of Nil and Karen Guillet through the State PoliceCentral Criminal Intelligence Unit (CCU). On 09106lIl, I received Guillefs tax records from the yearsof 2007 through 2010. The records showed Nil (husband) and Karen Guillet's joint Federally AdjustedGross Income to be as follows:a. 2007-$82,876.00

b.2008-$103,740.00c. 2009-$100,752.00d. 2010-$29,092.00

112) On 02/16/11, I obtained a written statement from the First Selectmanrs Administrative Assistant, JoeCalabrese. Calabrese stated the verification and depositing of monies from the tax collector's office wasleft to the discretion of the tax collector. Furthermore, deposits were also not verified by any other personprior to being brought to the bank.113) On 09/2g/Il, I spoke with Naugatuck Valley Savings and Loan Bank Manager Christina Stone. She statedshe was aware of the ongoing investigation into Guillet. She further stated she was working at theSeymour brancl of Naugatuck Valley Savings and Loan when the towlr_ opened the account a few yearsago. Stone was later transferred to the Oxford branch. Stone stated that Guillet always dropped off thedeposit bags for the tax collectorls office. She further stated other tovm=employees such as Hliva woulddrop offthe deposit bags for the town account but not for the tax collector's office.1 14) Stone informed me there was a bank log that documented who dropped off deposit bags. She stated shewas unable to provide me with hard copies of the log without a court order. A search warrant was thenapplied for and granted to seize the deposit bag drop off log. The information contained within the drop

logs would substantiate Stone's statements that Guillet was the only,person she knew of that dropped offdeposits for the Town of Oxford Tax Collector's Office. This information would also show that Guilletwas the only person who possessed the bank deposits from town hall to Naugatuck Valley Savings andLoan.


(This is page 25 of::a 27 pageAtfrdavlt,)


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ARREST WARRANT APPLICATIONJD-CR-Ma Rev- 3-11C.G.S. S 54-2aPr. Bk. Sec. 36-1, 36-2. 36-3Name {Lasl First, Middle lnitial)Guillet, Karen

STATE OF CONNECTICUTSUPERIOR COURTwww.jud.ct.govGeographicalArea number 5

Affidavit - Continued115) On 10/14/11, Sergeant Kline and I executed the search waffant at Naugatuck Valley Savings and Loan inOxford. We seized fifteen (15) pages of the deposit bag drop off log. The dates covered in those fifteen(15) pages were 07102/08 to 0lll2ll0. The pages seized were assigned Exhibit #11.

116) Contained within the deposit bag drop off log Guillet's name appears ninety-nine (99) times during theaforementioned time period as being the person who dropped off a deposit bag. Hliva's name alsoappears on the log twenty (20) times, but as Hliva and Stone stated the deposits were not for the taxcollector's office. There were other town employees that dropped off deposit bags as well, but there hasbeen no indication that anyone besides Guillet dropped off deposit bags for the tax collector's office.Furthermore, Hliva has indicated other town employees besides himself have dropped off the deposit bagsfor the town account, but never for the tax collector's account. In addition to the evidence compiled tosubstantiate the aforementioned lapping scheme is evidence tracing the funds directly from the tax payerthrough the tax office and into the hands off Guillet, who as described above, was the only persondelivering the deposit bags to Naugatuck Valley Savings and Loan.

117) On I0/03/I1, Hliva provided me with the State of Connecticut "Municipal Fiscal Indicators" reports forthe years 2002 to 2009. The Municipal Fiscal Indicator Report is a publication that consists of the mostcurrent financial information available for each of Connecticut's 169 municipalities. The majority of thedata has been compiled from the audited financial reports of municipalities.

118) Hliva compiled information from the Municipal Fiscal Indicators report supplied to him by the state andthe past fiscal indicator information he had on file in Oxford. He then composed a spreadsheet using theinformation in the fiscal indicator reports. The reports show that the Town of Oxford was last or secondto last (168 or 169 out of 169) in the Total Collected as a Yo of Totaloutstanding Taxes category eachyear for the fiscal years 1 999 to 2009.

119) This information gives considerable weight to the probability that Guillet has been embezzlingmoneyfrom the tax collecto*soffice well before the three (3) years of larceny outlined;in this affidavit.120) On 02110/11, I was supplied with Guillet's attendance records. Guillet rarely took a day off from work

and from 2000 to 2009 Guillet had lost nearly one-hundred (100) days of leave that she was entitled to.With regards to the aforementioned days of suspect bank transactions Guillet was present at work nearlyevery day. I cross referenced days of suspected criminal activity to Guillefs attendance records. Inreference to dates referenced in this afhdavit I found two (2) days when Guillet did not work at least% ofthe day. Those days are 05/13/08 (vacation day), and 07117108 (funeral).

121) Guillet's Bank of America statements showed there was over $199,000 in payments to American Express26 of a 27 pageAffidavit.)


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ARREST WARRANT APPLICATIONJD-CR-64a Rev.3-11C.G.S. S 54-2aPr. Bk. Sec. 36-1, 36-2, 36-3NameGuillet, Karen

STATE OF CONNECTICUTSUPERIOR COURTwww.jud.ct.govGeooraohicalArea"nrrmher 5

Affidavit - Continuedfrom 12112/06 to 021051rc. The American Express records show Guillet made $113,915.95 in paymentsfrom 02101/07 to 07102110, roughly the same time frame. Guillet's American Express statements show apattern of excessive spending on merchandise not necessary for everyday living. As stated earlier, thespending was mostly spent at clothing and department stores, hotels, casino, spas and salons.

122) This affidavit and the investigation conducted by the State Police depicts a relatively small portion of theimmense larceny, both in regards to the length of time and the amount of money stolen by Guillet.Therefore, of the one-hundred (100) sample batches manipulated and altered by Guillet, the investigationshows that at least $243,902.18 was proven to be embezzledby Guillet with supporting documentation.This is supported by the cash posting in the Quality Data Software compared to the actual bank validateddeposit slips. The investigation has shown that after the entoies were made in the Quality Data Software,Guillet would alter or fabricate a fraudulent deposit slip to reflect the amount of money that she wanted todeposit while keeping a portion to herself. This is not withstanding the overall lapping scheme which wasused to conceal her larceny by creating the illusion that everything'was in balance.

123) Based upon the aforementioned facts and circumstances, the affiant believes probable cause exists to showKaren Guillet embezzled approximately $243,902.18 over the course of 2008, and 2009. The affiant alsobelieves probable cause exists to show Guillet forged at least six (6) deposit slips in 2009. The affiantrequests that an arrest warrant be issued for Karen Guillet DOB 12124149 charying her with Larceny in thelst Degree (53a-I22) and six counts of Forgery in the First Degree (53a-138).

124)Thatthis affidavit has not been presented before any otherjudge or court.

(This is page 27 of a 27 page .Atfidavit.):

Guillet Warrant

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