14-104 J Rage 1 oF 3. IN THE CIRCUIT COURT THE SEVENTH JUDICIAL CIRCUIT COURT F iL E Dp SPRINGFIELD, SANGAMON COUNTY, ILLINOIS TANCE 2H CRE People of the State of Illinois, ) | ee Clerk of the | Plaintiff, > Ad, Pet, Circuit Court | avs ) No. 2014-CF-1041 | ) Margaret Curtin, ) | Defendant. ) | PEOPLE’S FIRST AMENDED MOTION TO ADD COUNTS NOW COME, the People of the State of Illinois, by John C. Milhiser, State’s Attomey of Sangamon County, who hereby moves the Court, pursuant to 725 ILCS 5/111-2(f), to enter an order allowing the People to add additional counts of Forgery under 720 ILCS 5/17-3(a)(1), of Wire Fraud under 720 ILCS 5/17-24(b), and of Money Laundering under 720 ILCS 5/29B- 1(@)(1). In support of said motion, the People state to the Court as follows: 1. On September 23, 2014, Defendant Curtin was charged through complaint under 720 ILCS 5/16-1(a)(2) with one count of Theft. 2. On October 16, 2014, Defendant waived her right to preliminary hearing, ‘The People were granted leave to proceed by filing a-one-count information alleging the offense of | Theft. 3. Under 725 ILCS 5/111-2(8), where a case is brought by information and following preliminary hearing or the waiver of preliminary hearing, such prosecution may be for all offenses arisiig from the same transaction or conduct of the defendant, even though the complaint filed at the preliminary hearing charged only some of the offenses arising from that transaction,fo ly-ce- lou | 5 Pager 3 4. The proposed counts of Forgery for violation of 720 ILCS 5/17-3(a)(1) (attached hereto as Exhibits A — G), the proposed count of Wire Fraud for violation of 720 ILCS 5/17- 24(b) (attached hereto as Exhibit H), and the proposed counts of Money Laundering for violation of 720 ILCS 5/29B-1(a)(1) (attached hereto as Exhibits I and J) arose from the same course of conduct undertaken by defendant that resulted in the charge contained in the current information. | 5. The defendant is not in custody and the case is presently scheduled for trial on January 12, 2014. 6. This motion is filed in the interest of justice and not for the purpose of harassment or delay. The new charges do not constitute an unfair surprise in that the new charges allege the ‘means by which Defendant undertook the theft already charged and the uses of the funds thus derived. PRAYER FOR RELIEF: WHEREFORE, premises considered, the People pray that this honorable Court will enter an order, pursuant to 725 ILCS 5/111-2(6), allowing the People to add seven additional counts of Forgery (720 ILCS 5/17-3(a)(1)), one count of Wire Fraud (720 ILCS 5/17-24(b)), and two counts of Money Laundering (720 ILCS 5/29B-1(a)(1)). C. MILHISER STATE'S ATTORNEY John C. Milhiser j Sangamon County State’s Attomey | 200 So. Ninth Street, Room 402 Springfield, IL 62701 (217) 753-6690a 14-cP-436 Page 3 of 3 PROOF OF SERVICE The undersigned hereby certifies that service of the foregoing document was made by enclosing a true and correct copy thereof in a sealed envelope, postage fully prepaid, addressed to: Peter Wise Attomey at Law 1231 S. Eighth St. Springfield, IL. 62703 and depositing the same in the United States Mail from the office of the Sangamon County State's Attomey’s Office on January 6, 2015.| | | 14-CF-1041 Count IT of XI Page 1 of 10 ‘And the said State’s Attomey in and for the County and State aforesaid, in the name end by the authority of the People of the State of Illinois aforesaid, gives the Court to further understand and be informed that one MARGARET CURTIN, between the Ist day of December, in the year Two Thousand and Seven and the 31" day of December, in the year Two ‘Thousand and Eight, and within the County of Sangamon and State of Illinois, committed the offense of FORGERY, in that said defendant, with intent to defraud, knowingly made false documents apparently capable of defrauding another in such manner that they purport to have been made by another, “M/LIC Associates”, said documents being eleven invoices numbered 2007-1802 through 2008-1981 claiming fees due for “Membership in OLM Expanded Database”, in violation of the Criminal Code of 2012, as amended, 720 ILCS 5/17-3(a)(1) and against the peace and dignity of the same People of the State of Illinois. Cue Tee's Aownay in and for sald Sangamon County. 14-CF-1041 Count Ill of XT Page 2 of 10 ‘And the said State’s Attorney in and for the County and State aforesaid, in the name and by the authority of the People of the State of Illinois aforesaid, gives the Court to further | understand and be informed that one MARGARET CURTIN, between the Ist day of January, in the year Two Thousand and Nine and the 31* day of December, in the year Two Thousand and Nine, and within the County of Sangamon and State of Illinois, committed the offense of FORGERY, in that said defendant, with intent to defraud, lnowingly made false documents apparently capable of defrauding another in such manner that they purport to have been made by another, “M/L/C Associates”, said documents being eleven invoices numbered 2009-835 through the Criminal Code of 2012, as amended, 720 ILCS 5/17-3(a)(1) and against the peace and | 2009-13857 claiming fees due for “Membership in OLM Expanded Database”, in violation of dignity of the same People of the State of Illinois. Slate's Attorney in and for said Sangamon County, / PEOPLE'S | | Gee B14-CF-1041 Count IV of XI Page 3 of 10 ‘And the said State’s Atiomey in and for the County and State aforesaid, in the name and by the authority of the People of the State of Illinois aforesaid, gives the Court to further understand and be informed that one MARGARET CURTIN, between the Ist day of January, in the year Two Thousand and Ten and the 31" day of December, in the year Two Thousand and FORGERY, in that said defendant, with intent to defraud, knowingly made false documents apparently capable of defrauding another in such manner that they purport to have been made by another, “M/LIC Associates”, said documents being twelve invoices numbered 2010-1020 through 7486-FY 2011 claiming fees due for “Membership in OLM Expanded Database”, in Violation of the Criminal Code of 2012, as amended, 720 ILCS 5/17-3(a)(1) and against the | | Ten, and within the County of Sangamon and State of Illinois, committed the offense of | peace and dignity of the same People of the State of Illinois. { ‘State's Attorney in and for said Sangamon County PEOPLE'S SGI ec14-CF-1041 Count V of XI Page 4 of 10 | ‘And the said State’s Attomey in and for the County and State aforesaid, in the name and by the authority of the People of the State of Illinois aforesaid, gives the Court to further understand and be informed that one MARGARET CURTIN, between the Ist day of January, in the year Two Thousand and Eleven and the 31" day of December, in the year Two Thousand and Eleven, and within the County of Sangamon and State of Illinois, committed the offense of FORGERY, in that said defendant, with intent to defraud, knowingly made false documents apparently capable of defrauding another in such manner that they purport to have been made by another, “M/LIC Associates”, said documents being ten invoices and two electronic invoices claiming fees due for “Membership in OLM Expanded Database”, in violation of the Criminal Code of 2012, as amended, 720 ILCS 5/17-3(a)(1) and against the peace and dignity of the same People of the State of Illinois. Que cma Siaie’s Attorney in and for said Sangamon County 13°) s aed Ba. 14-CF-1041 Count VI of XI Page 5 of 10 And the said State’s Attorney in and for the County and State aforesaid, in the name and by the authority of the People of the State of Illinois aforesaid, gives the Court to further understand and be informed that one MARGARET CURTIN, between the Ist day of January, in the year Two Thousand and Twelve and the 31" day of December, in the year Two Thousand and Twelve, and within the County of Sangamon and State of Illinois, committed the offense of FORGERY, in that said defendant, with intent to defraud, knowingly made false documents apparently capable of defrauding another in such manner that they purport to have been made by | another, “M/LIC Associates”, said documents being one invoice and eleven electronic invoices | claiming fees due for “Membership in OLM Expanded Database”, in violation of the Criminal | Code of 2012, as amended, 720 ILCS 5/17-3(a)(1) and against the peace and dignity of the same People of the State of Illinois. Gee oe Slate's Attorney in and for s ‘Sangamon County | | Ldsel a Ese i2GIENE: 14-CF-1041 Count VII of XI Page 6 of 10 | ‘And the said State’s Attorney in and for the County and State aforesaid, in the name and by the authority of the People of the State of Illinois aforesaid, gives the Court to further understand and be informed that one MARGARET CURTIN, between the Ist day of January, | in the year Two Thousand and Thirteen and the 31* day of December, in the year Two Thousand | | and Thirteen, and within the County of Sangamon and State of Illinois, committed the offense of FORGERY, in that said defendant, with intent to defraud, knowingly made false documents apparently capable of defrauding another in such manner that they purport to have been made by another, “M/LIC Associates”, said documents being one invoice and ten electronic invoices claiming fees due for “Membership in OLM Expanded Database”, in violation of the Criminal Code of 2012, as amended, 720 ILCS 5/17-3(a)(1) and against the peace and dignity of the same People of the State of Illinois. Gee oa ‘State"s Attorney in and for said Sangamon County | |14-CF-1041 Count VIII of XI Page 7 of 10 And the said State’s Attorney in and for the County and State aforesaid, in the name and by the authority of the People of the State of Ilinois aforesaid, gives the Court to further understand and be informed that one MARGARET CURTIN, between the Ist day of January, in the year Two Thousand and Fourteen and the 31% day of August, in the year Two Thousand and Fourteen, and within the County of Sangamon and State of Illinois, committed the offense of FORGERY, in that said defendant, with intent to defraud, knowingly made false documents apparently capable of defrauding another in such manner that they purport to have been made by another, “MIL/C Associates”, said documents being nine electronic invoices claiming fees due for “Membership in OLM Expanded Database”, in violation of the Criminal Code of 2012, as | amended, 720 ILCS 5/17-3(a)(1) and against the peace and dignity of the same People of the State of Illinois. Gee our ‘State's Attorney in and for said Sangamon County bse) na EXHIBIT = — 414-CF-1041 Count IX of XI Page 8 of 10 | ‘And the said State’s Attorney in and for the County and State aforesaid, in the name and | by the authority of the People of the State of Illinois aforesaid, gives the Court to further | understand and be informed that one MARGARET CURTIN, between the Ist day of July, in | the year Two Thousand and Twelve and the 31" day of July, in the year Two Thousand and Fourteen, and within the County of Sangamon and State of Illinois, committed the offense of WIRE FRAUD, in that said defendant devised 2 scheme to obtain money by means of false pretenses or representations, namely false electronic invoices, and, for the purpose of executing said scheme, transmitted or caused to be transmitted writings, signals, or electronic impulses by | means of wire from within the State of Hinois or so that the transmission was received by a | person within the State of Illinois, in violation of the Criminal Code of 2012, as amended, 720 ILCS 5/17-24(b) and against the peace and dignity of the same People of the State of Illinois. Ore oar Slate's Attomey in and for said Sangamon County PEOPLE Se H14-CF-1041 Count X of XI Page 9 of 10 ‘And the said State’s Attomey in and for the County and State aforesaid, in the name end by the authority of the People of the State of Illinois aforesaid, gives the Court to further understand and be informed that one MARGARET CURTIN, on or about the Ist day of December, in the year Two Thousand and Seven through the 30" day of September, in the year Two Thousind and Fourteen, and within the County of Sangamon and State of Illinois, committed the offense of MONEY LAUNDERING, in that said defendant, knowing that the property involved represented the proceeds of unlawful activity, conducted financial transactions, being deliveries of checks, deposits, withdrawals, transfers between accounts, purchases, payments, and loans, which in fact involved criminally derived property exceeding $500,000, with the intent to promote the carrying on of the unlawful activity from which the criminally derived property was obtained, in violation of the Criminal Code of 2012, as amended, 720 ILCS 5/29B-1(a)(1)(A) and against the peace and dignity of the same People of the State of Illinois. Qe oe ‘State's Attomey in and for said Sangamon County14-CF-1041 Count XI of XI Page 10 of 10 ‘And the said State’s Attorney in and for the County and State aforesaid, in the name and by the authority of the People of the State of Illinois aforesaid, gives the Court to further understand and be informed that one MARGARET CURTIN, on or about the Ist day of December, in the year Two Thousand and Seven through the 30" day of September, in the year Two Thousand and Fourteen, and within the County of Sangamon and State of Illinois, committed the offense of MONEY LAUNDERING, in that said defendant, knowing that the property involved represented the proceeds of unlawful activity, conducted financial transactions, being deliveries of checks, deposits, withdrawals, transfers between accounts, purchases, payments, and loans, which in fact involved criminally derived property exceeding $500,000, and knew or reasonably should have known that these financial transactions were designed in whole or in part to conceal or disguise the nature, location, source, ownership, or control of the criminally derived property, in violation of the Criminal Code of 2012, as amended, 720 ILCS 5/29B-1(a)(1)(B) and against the peace and dignity of the same People of the State of Illinois. “Gates Attomey in and for sald Sangamon County