Hildebrandt Investigation
State Attorney's Office
2" Judicial Circuit
Investigator Doug Paul
31 October 2014
On 31 October 2014, I was asked to determine if an allegation of theft at Lively
‘Vocational and Technical School was being worked by any local agency. Our office was
approached by the school board who indicated that the Leon County Sheriff's Office and
the Florida Department of Law Enforcement had been notified but it did not appear that
any action had been taken, I was able to determine that the Florida Department of Law
Enforcement was loolcing at the case and I met with school board personnel ( Buddy
Triquet and John Hunkier ) to advise them of my finding. During my meeting, I was
furnished an investigative packet containing information regarding the case and | advised
‘Triquet and Hunkier that I would forward it the Florida Department of Law Enforcement.
The following week , I contacted FDLE agent Brett Lycett to discuss the case and
confirm that his office was moving forward with the investigation, I was advised that a
mecting was planned but no action had been taken since the packet was dropped off on 31
October. I therefore met with State Attorney Meggs to advise him of the progress and the
decision was made for our office to handle the investigation.
‘The school board provided me with the names of three employees and numerous
students that were enrolled in the welding class during the time of alleged theft. I made
contact with the students and instructors to take sworn recoded statements, The students
‘were no longer at the school and were working at different businesses in the Tallahassee
area. The instructors were interviewed at my office or at Lively in the welding shop. I have
listed an overview of their statements below.Page #2 ( Hildebrandt )
Joseph Andrew Lucia — Interviewed on 13 November 2014 at 1058 hours
He advised that he was a student at the welding school and remembered working on three
metal gates that were later installed at the Hildebrandt home. The material he used came
from a rack by the back door of the welding school, The racks contained metal materials
that would be delivered by (ruck after orders were made by school personnel, He was never
told to be sure to use material from a separate area that had been set aside for the
Hildebrandt gate project. After the gates were built and painted, he was asked by Mann
Roberts if he would help install them at the Hildebrandt home ( believed to be in 2011 ).
Lucia agreed and the gates were loaded onto a school trailer with some additional six inch
fat bar. He believed that it was loaded on a Thursday or Friday and they met at the school
on the following morning to move the items to the Hildabrandt home. Lucia drove with
another student (Kyle Williams) to the Hildebrandt home and stated that the trailer with
the gates and flat bar were already at the home when they arrived. He worked on the fence
and gates for one day and did not return the next day. He was not sure if anyone worked »
second day at the Hildebrandt home. After ending the tape, I thought of an additional
question regarding sod. I therefore started tlke recording a second time to diseuss missing
sod, Lucia advised that he remembered a large quantity of sod being delivered and he
thought if was too much sod for the area that needed to be covered. He did not see who laid
the sod but believed that it was the Hildebraudts. This concluded my interview with Joseph
Lucia.
Melford Eugene Sims — Interviewed 13 November 2014 at 1400 hours
Melford Sims is a welding instructor at Lively Votech and I started the interview by
showing him several photographs of the Hildebrandt property. The pictures included the
large main gate at the Hildebrandt home ( picture # 4 ), one of two smaller yard gates
(picture #2), and installation of six inch flat bar fencing at the main gate ( picture # 1).
Sims explained that the yates depicted in the photographs were built at the school using
school materials. He aiso advised that the main gate was built and installed prior to the
smaller gates and the six inch flat bar fencing. He believed that Mann Roberts and students
from Lively Welding helped him installed the main gate but was vague about the exact
date. He remember more details about the two smaller fences and the six ineh flat bar. Sims
explained that everyone met at Lively ( believed to he on a weekend morning ) and the two
smaller gates were retrieved from inside the welding shop, The six inch flat bar was pulled
from the steel pile located behind the welding shop. The items were loaded onto a lively
‘railer and transported to the Hildebrandt home for installation, I then produced pietare
#3 which Sims described as Ira Schul (Lively Student ) installing 2 chain hoist on an
L-Beam at the Hildebrandt ranch. Sims stated that the chain hoist locked like a hoist that
was missing from the school. Sims brought the missing hoist to the attention of Mann
Roberts and was told that it had been taken to the Hildebrandt ranch. Sims admitted that
he actually worked on the I-Beam and hoist at the Hildebrandt home,Page #3 ( Hildebrandt )
We then spoke about a delivery of sod that was purchased by the school. Sims remember a
{ange sod delivery and he described it as alot of sod ”, He said it was enough to do the job
and then some, He also heard that there was sod left over and believed it to be three or four
pallets, He remembered seeing some of the left over sod behind building # 6 but does nc!
{new what happened to it. We then discussed missing Stall mats that hed been purchased
by the school. Sims remembered seoing mats under an awning at building # 16. They were
stacked on pallets but he was unsure of the exact number. He described them by saying
{hat id was a large enough number that a fork lft could barely lift them. Sims believed that
mats were ordered for some type of event at the school but he does not know what
happened to them. Timesheets was the next topic we discussed Sims explained that he was
‘nially told by Mann Roberts to pad his timesheets with extra hours during the sumaner to
pay Bailey Hildebrandt between two and three hundred dollars a week, Sime first told
Maan Roberts that he was not comfortable with padding his time sheets but Woody
Hildebrandt came to hins and asked hin to add time for Bailey. Sims felt pressured to
comply because he was just getting tenure and was worried about his job. Fe stated that he
paid Baily twice which was later determined to be in the summer of 2011. Sims knew that
he was violating school poticy but his concern for him job was the overriding factor. He
only paid Bailey twice and it was for ome summer period. We thea discussed a trucks thet is
{@ the back lot of the Welding School. Iwas told by Buddy Triguet with Leon County
Schools that the truck had been donated to the sehool by Mann Roberts and that Woody
Hildebrandt told Roberts that he could fake metal stock as payment since the school
couldn’¢ reimburse him for the truck. Sims stated that he was told that Roberts donated
the truck to the school but he did not have any additional information on the topic. Tervis
Tumbler racks were the next item to be discussed. Sims told me that students worked on
completing them during the day and that he helped tack them up. When I asked Sims what
happened to them after they were completed, he told me Woody was picking them up to use
or the Topsy Tervy cups. It should be noted that Woody Hildebrandt’s wife, Joni, hav a
Tervis Tumbler business and she uses racks to display the eups. H nquired about the
Stainless steel rods that were used to build the racks and Sims believed they were ordered
by Mann Roberts. Sims couldn't remember the exact dates that the racks were built but
Knew that it was after he altered his timesheets. My last question was to confirm that metal
stock used for the Hildebrandt projects came from school supplies .1 asked Sims if he was
ever fold to use metal from a separate area that was purchased by Woody Hildebrant for
the projects af the Hildebrandt home. Sints stated that all the material used came from the
school stack and that he was never aware of any material purchased by Woody
Hildebrandt,Page #4 ( Hildebrandt )
Ira Daniel Schul - Interviewed 14 November 2014 at 0900 hours
{spoke with Schul a¢ his place of employment ( Bettinger Welding ) and he advised me that
ke was a sindent at the welding sehool prior to his employment at Bettinger, He explained
that he worked on the Hildebrandt front gate and even cut plates for the gate motor eontrol
frm. He stated that the main gate was built at the school welding shop using school stock,
but he was mot at the Hidebrandt home when the main gate was installed. Ail the material
used on the gates came from metal at the school and at no time was he instructed to ase
material from a different ares that was provided my Hildebrandt, He did respond to the
home to install the control arm plates on the main gate and also made a separate trip fo
install a chain hoist trolley system in the barn area, The welder pictured in photo #2 is a
school welder and it was pulled to the Hildebrandt home on the day he installed the control
arm plates. He brought the plates for the main gate from the sehool but advised that the I.
Beam and chain hoist were already at the Hildebrandt home on the day that they were
installed. Schul farther advised that the school had I-Beam stock that was donated to the
school and also had a chain hoist of similar size and color.
‘We then discussed che stall mats that were missing from the school, Schul didn’t remember
secing any mats and had no knowledge of them being taken from the school. Laiso asked
tim about the missing sod and he did remember secing semi trucks of sod being delivered.
He explained chat perimeter gates were installed around the schoo! and the sod-was
ordered to fil in areas around the gates. Schul remembered secing approximately two
Pallet left over and he told me that he helped load them on a school trailer. He is aot care
what happened to the extra sod,
Schul aso remembered seeing both of Hildebrandt’s sons working at the school during the
Summer, He explained they worked odd jobs like pressure washing and cutting grass.
When asked if they were being paid by the school, Schul advised me that they were paid by
Mann Roberts and Melford Sims. He stated that ke was told by Roberts and Sims thot
Woody Hildebrandt asked them to write in extra time on their timesheets to pay them,
Roberts and Sims did not itke the idea and complained verbally to Schul during separate
conversations,
Kyle Dean Williams — Interviewed 14 November 2014 at 1520 hours
“spoke with Williams at the Sewage Treatment Plant on Springhill road and he advised me
that he was attended Lively Welding School but graduated and was now employed as a
welder. We first disenssed picture #4 and he recognized them as gates that were worked on
by various students in the welding program, Williams advised that he worked on the two
main gates but he did not help install them. He explained that the metal used for the main
Sates came from metal stock used by the school for all projects. He told me that all metal
Stock was orderes by the school, delivered to 2 fence area behind the welding school, and
{hen off loaded by a student or instcuctor who knew how to operate the fork lift. The stock
would then be placed on racks and used as needed by the students. Williams knew that the
main gates were being built for Woody Hildebrandt and he was never instructed to use
material from any other area. He did uot see the main gates installed until he was at the
Hildebrandt home to install two smailer gates and metal fencing,Page # 5 ( Hildebrandt )
He continued by saying that they loaded the two stealler gates and fence material on a
Gtailer at the school and then met at the Hildebrandt home the following morning to install
the gates and fencing, He described picture # 1 as students and instructers welding the six
inch fat bar into position for the fencing next (o the main gate. He wasn’t sare why, puiled
the trailer (o the Hildebrandt home or what day it was taken, We then disenesed picture #2
Which depicted one of the smailer gates that Williams helped install, Williams deveniban
{hat picture as an unknown male standing next to one of the smaller gates and one of
Lively’s welders ia the scene. I then showed Williams picture #3 and he identified Ira
Schul in the photograph and stated the I-Beam looked similar 10 I-Beam at the schost
Williams remember that the I-Beam at the school had yellow paint on it and had becg
donated to the school. When asked if he had ever worked off eampus on any other project,
Williams told me that the Hildebrandt project was the only time ine ever werk. away from
the schools I then inquired about the stainless steel racks that were built for the Teeve,
Tumbler display and Williams kad no knowledge of that project.
Sod was the next topic that we diseussed and Williams remembered seeing a large quantity
of sod being delivered. He thought that it was too much sod for the area that wae te he
covered. Williams said there were pallets left over from the job and he believed that i was
approximately four to seven pallets. The pallets were at the school when he left for the day
and they were gone whten he returned, He cannot remember if it was overnight or over a
weekend,
Stall mats were also discussed and Williams stated that he never saw any mats at the school
during his enrollment,
Williams did remember seeing one of Hildebrandi’s sons working at the school over the
fuminer Dut wasn’t sure if he was employed by the school, He explained that the work
being done hy Hildebrande’s son most mostly odd jobs ( cleaning up, etc).
Floyd (Mann ) Roberts - Interviewed 19 November 2014 at 0945 hours
According to Mann Roberts, he attends the same church as Tina Brown and she told him
at charch that Jackie Pons may want (o talk to him. Roberts became nervous and decided
{o hire a lawyer. He told me that he worried about the Hildebrandt projects and the
timekeeping discrepancies. Roberts therefore hired Attorney Andrens and he spoke wit
bie about the setivities at the school. Attorney Andrews decided to call the MBI and aaivise
them of the information. The next day, Roberts arrived at work ( approximately 0745 ) and
Feceivei a telephone call from Woody Hildebrandt. During the call, Hildebrandt asked
Roberts if he was alone in his truck and Roberts advised him that he was alone in his offiee,
Hildebrandt asked hima ifhe had spoken with the FBI and Roberts told him that he hed not
spoken with them. Hildebrandt then stated “ I will be down to see you later ” but according
she Roberts, Hildebrandt never responded to his office. Roberts then received » eall reve
Pons who wanted him to respond to his ( Pons? ) office. The request was regarding a
student complaint about the instructor/student ratio but Roberts did not keow that at the
time,Page #6 ( Hildebrandt )
This made Roberts even more nervous and after he met with the student about the ratio
issue, he decided fo sit down with Pons and tell him what was going on at the Welding
school, After receiving the information, Pons asked his investigators to determine if the
complaint had any merit and they began an investigation. It was determined that the
information had merit and Pons thought it would be best fo have an outside agency look
into the matter.
Once Ihad a basic understanding of how the case initially started, I became more specific
with my questioning of Roberts, We first discussed photograph # 4 and Roberts described
it as a photograph of the Hildebrandt main gate, He stated that the Heck Ranch logo, the
metal ducks and the decorative designs in the center of each gate were purchased by
Hildebrandt. However, the rest of the gate material was from Lively Welding School.
Roberts continued by saying that ke built the gates with kelp from students and then
transported them to the Hildebrandt home. The flat bar used to design the fence on both
sides of the gate also came from the school and were install at a later date.
Photograph # 1 was viewed next and Roberts identified several people to include
instructors and students. This was a photograph of the fence sections next to the main gate
and Roberts said that he was the person taking the photographs, He told me that the flat
Dar in the photograplt was metal from the school, Roberts was then shown photograph # 3
and he identified the person on the ladder as a Lively Welding student with his hand on a
‘monorail system that was installed on the Hildebrandt property. He told me that the I-
Beam was from the surplus behind the welding school and the chain hoist was from the
automotive shop, When asked how he knew that the hoist was from the school, ke stated
that Hildebrandt told him retrieve it and take it (o the Hildebrandt barn. Roberts then
looked at picture # 2 and advised me that it depicted Taylor Hildebrandt standing next to x
gate while another person welded on hinges Roberts told mze that two gates were built like
the one in photograph # 2 and that he took the picture, He continued by telling me that two
gates were built in that design and that both were built with school material prior to
transporting them to the Hildebrandt home. He also said that the welding machine in the
photograph was school property and was taken to the area to weld sections of the gates.
‘When I asked if Hildebrandt personally supplied any of the materials for the gates ( with
the exception of the decorative items ), fence, I-Beam or Hoist, Roberts told me that all the
material was from the school.
Bailey Hildebarndt’s summer employment was then discussed and Roberts told me that he
was not employed by the school but worked at the seliool for two summers, I asked Roberts
who was paying him if he wasn’t a school employee and he advised me that Woody
Hildebrandt told him to pay Bailey $200.00 per week. Roberts stated that he was told by
Woody Hildebrandt to pad his hours to cover the $200.00 per week. Roberts complied and
paid Bailey $800.00 for three months in 2011 ( $2400.00 Jand for three weeks in 2012
($600.00 }. Fhe $600.00 summer ( 2012 ) ended the payments because Roberts decided to
stand his ground and stopped paying Bailey. He stated that Woody Hildebrandt kept
pressuring him to pay his son and Roberts retrieved the money for three weeks, He met
with Baiiey, paid him the money and told him to tel! his father that he wasn't going to do it
anymore, Bailey told him that he understood and this ended the practice with Roberts, This
practice of paying Bailey with padded overtime hours also invelved two other instructors
(Melford Sims and Keith Moere).Page #7 ( Hildebrandt)
We then discussed missing sod from the school and Roberts explained that three tractor
traller truck loads were ordered to complete a job at the school. He stated that new fencing
had been installed om the schools perimeter aisd the sod was going to fill in along the fence
line. Roberts told me that approximately one half to three quarters of a semi trailer load of
sod was left over after the perimeter fence job was complete. Roberts did not see what
happened to the extra sod but heard that it was being taken (o the aviation school.
Mats were our next topic of conversation and Roberts remember that mnats were being
ordered fo display vehicles in the automotive school. Fle continued by saying that
approximately 40 mats were needed for the display but more than 40 were ordered. The
extra mats were taken to a building near the motoreycle training area to be stored. He did
admit to using some of the mats (approximately 20 ) for flooring in a gym area at the
welding school. There were additional mats left over but they are no longer at the school,
When asked, Roberts told me that he bias seen mats at the Hildebrandt home and they
appeared after the ear show. He had never seen mats at the Hildebrandé property prior to
the show,
‘We then diseussed Tervis Tumbler racks, Roberts was familiar with the racks and said that
they were built from stainless steel stock at the school. He built the racks with the help of
Melford Sims, John Scott, and numerous students, He told me that Hildebrandt did not
pay for the racks and they were going to be used for the Hildebrandt’s Tervis Tumber
business. Roberts believes that approximately 12 to 16 racks were built. Some of the racks
were delivered to the Hildebrandt home and the others were picked up at the school by
Hildebrandt. In addition (0 the racks, approximately six shelving units were purchased
with school funds and modified at Hildebrandt’s request. The shelving units (cabinets)
were purchased from Lowes and then modified to meet Hildebrandt’s requirements. This
included some stainless steel rods and wheels for the base 50 that they could be moved
easily. The racks mentioned earlier im this statement were then zip tied to the sides of the
cabinets for extra Tervis Tumbler storage.
Prior to the completion of this interview, I readdressed the main gate at the Hildebrandt
home, I talked about the ornamental items on the gate fo include the ducks, center logos
and the Heck Ranch name, All of these items had been purchased by Hildebrandt and
installed on the gates made at the school. Flowever, the Heck Ranch logo was changed to
Hildebrandt and I wanted to have Roberts explain the change. Roberts told me that
Hildebrandt changed the name after the school purchased a plasma cutting machine. He
(Hildebrandt ) asked Roberts to make the change and Roberts used school material
(carbon steel plate ). The actual plate that the lettering was cut from was located at the
welding school and has been collected by Investigator Triquet at my request.
Keith Moore — Interviewed 19 November 2014 at 1145 hours
Tspoke with Keith Moore in my office and he explained that he is Hildebrandt brother in-
law. In addition, he became involved after Roberts spoke with the school board and
brought up his mame. I started by showing him picture # 4 and he deseribed it as a picture
of the Hildebrandt main gate. He told me that he has been on the property numerous times
because his sister is married to Hildebrandt, He had no knowledge of the gates construction
or installation.Page #8 ( Hildebrandt )
1 then ask him about the chain hoist which is depicted in photograph #3 and he ¢old me
that the hoist was in the automotive section at Lively and was being taken out of service,
Hildebrand: thought that it was something that his sons cowld use at the Hildebrandt home
to work on vehicle, He has seen the hoist installed on the back side of the barn on an I-
Beam systera. The hoist as not been seen at the school since that time.
‘We then discussed Bailey Hildebrandt and Moore said that he worked at the school during
the summers and he was told by Woody Hildebrand to pad his hours so that he could pay
Bailey $10.00 per hour. Moore complied and paid bailey $400.00 per week for a total of
$1600.00 per month. Moore would pad his time on Fridays and Saturdays when he was
normally off. This took place over two summers and Moore felt obligated because
Hildebrandt made sure ke knew that he ( Hildebrandt ) helped him get the Lively job.
Sod was then discussed and Moore told me that three truckloads of sod was order to place
around the school and there were 16 pallets ieft over, Hildebrandt told Moore that there
was nowhere else to put the extra sod and that if would go bad, He then asked Moore if he
needed any sod and Moore told him that he could use some at his home. Ten pallets were
therefore taken te Moore’s home on a 40 foot Lively trailer by Hildebrandi’s sons. Once it
arrived, Moore and both of Hildebrandt’s sons placed the sod in Moore’s yard. The
remaining six pallets were taken to the Hildebrandt home and Moore helped lay the sod in
a ditch just inside the main gate. Moore explained that his help with the sod at the
Hildebrandt home was his way of repaying Hildebrandt for the ten pallets he received.
Our conversation then turned to stall mats and Moore told me that they were originall
purchased for a school automobile display. After the car show the mats were used in
several areas around the school. Moore seemed surprised when I told him that at least 150
mats had been ordered and he stated that it was more than the amount still at the school,
‘When asked if he had ever seen mats at the Hildebrandt home prior to the car show, Moore
advised me that he liad not, He also told me that because of the family ties, he had been on
the property numerous times over the past nine years, Since the show, he has seen a large
Number of rubber mats in the barn area of the Hildebrandt home, The mats covered an
area that he described as 40x40 feet. He never saw anyone take mats to the Hildebrandt
home and had no additional information,
‘We then talked about Tervis Tumblers and he told me that his sister has a Tervis Tumbler
business. He saw the racks that she uses being modified at the Lively welding school.
Students were installing wheels so that the racks could be moved easily. Meare said that the
racks are stored on the Hildebrandt property and be has helped his sister at several events
where the racks were used. He was uot familiar with the stainless steel additions to the
racks.
Moore then told me about a window seat that he built for the Hildebrandt home. He
explained that Hildebrandt approached him and wanted him to build 2 wooden windo seat
for his home. Moore is the instructor in the building class at Lively and agreed to build it,
‘The seat took approximately 15 hours to build and all the materials came from the school.
Onee finished, he put the cabinet in Hildebrandt’s truck and met him at the Hildebrandt
home for installation, He described the window seat as s lift up design and it was installed
under windows in the living room. The seaf is a permanent addition to the living room and
Moore believes that it should still be in the home.Page #9 ( Hildebrandt)
The last topic discussed was epoxy paint. Moore told me that he needed to paint the floor in
the construction area and noticed that another ares had used epoxy paint to resurface the
floor. Moore like the results and deci
inal floor that he saw had been painted in a gray color but he decided to do his section
a beige finish, Hildebrandt saw the floor after it was completed and told Moore that he
would like the same finish on his garage floor, Moore therefore ordered Moore paint and
finished Hildebrandt’s garage in the same color. Moore believed that he ordered 6
sdditional gallons were ordered for the Hildebrandt home.
Moore then ended our conversation with information about a telephone eail he received
from Hildebrandt, Moore told me that he received the call on Thursday ( November 13,
2014) and Hildebrandt told him that Mann Roberts had come forward as a whistle blower.
Hildebrandt explained to Moore that Investigator Triquet might be stopping by to talk
with him (Moore ). Hildebrandt told Moore that they needed to get their stories straight
and that Triquet would be asking about the sod, and the padding of the timesheets.
Hildebrandt said if the sod issue come up, Moore should tell Triquet that the left over sod
Was put in front of the schocl. Hildebrandt also told Moore to tell Triquet that Bailey was
paid out of pocket. Moore did not provide me with any additional information during the
interview.
Based on the interviews, I began collecting evidence to verify the information provided. It
was already established that the gates and fence were on the Hildebrandt property.
Promotionat You-Tube videos for the school show welding students building one of the
corral gates, and numerous photographs show instructors and students installing the gates
and fence on the Hildebrandt property. The fabrication and installation of these items were
well documented, I therefore secured am itemized list of materials used to build the gates
and fence from Floyd (Mann ) Roberts which included material cost and labor rates. After
securing the itemized list, I took the list to Metal Fabrication and Sales of Tallahassee and
met with Len Turner, He reviewed the material listed and gave me their cost breakdown
for materials and labor. Their breakdown exceeded that of Floyd Mann Roberts. f have
listed the information below:
Main gate estimate ( Floyd Roberts ) Main Gate Estimate (Metal Fab )
Material - $1693.56 Material - $3416.80
Labor - $17,290.00 Labor — $20,020.00
Corral Gates (Floyd Roberts } Corral Gates (Metal Fab )
Material - $1211.76 Material - $1494.56
Labor - $12,920.00 Labor - $14,960.60
Monorail System { Floyd Roberts ) Monorail System ( Mletal Fab )
Material - $2305.30 Material - $2392.80 ( using same Hoist info )
Labor - $6840.00 Labor - $7920.80
Combined Total - $42,269.62 Combined Total - $50,204.16Page # 10 ( Hildebrand¢ )
‘The main gate, fence and one cerral gate could be seen from Mahan Drive but a search
warrant was obtained via Judge Flury (0 verify the additional corral gate and monorail
system. The search warrant was served on 19 December 2014 and the second corral gate
Was verified. The gate was located in the stable area on the Hilderandt property and
appeared to be the same dimensions as the corral gate outside. In addition, a smaller corral
gate was observed inside the stable area and it appeared ¢o be of the same design but
approximately half the length. Photographs were taken of all of the gates and fence and
have been attached to this report. Upon return the office, I contacted Floyd (Mann )
Roberts and he stated that he had forgotten about the smaller gate. He therefore provided
me with a cost and labor breakdown for the additional item.
Smaller Corral Gate ( Floyd Roberts ) Smailer Corral Gate ( Mietal fab )
Material- $272.76 Estimate not available
Labor - $2280.00
Combined Total - $2552.76
The interviews also produced information about shelving units that were built at the
request of Wilburn Hildebrandt. Floyd Roberts initially stated that six shelving units were
built and that wheels were installed on the bottom of each unit in an effort to make them
easier to move. The shelves were to be used by Joni Hildebrandt for her Tervis T umbler
business. According to Roberts, the shelves were ordered on a Lively account at Lowes and
Iwas able to locate several receipts from March 2012 indicating that materials to build the
shelves were secured via Lively purchase order. Mann Roberts reviewed the receipts and
advised me that it appeared the receipts had enough material listed to build 5 or possibly 6
shelving units, In addition to the shelving units, Hildebrandt asked the welding department
to fabricate a number of stainless steel racks. These racks were also designed to display
‘Tervis Tumbler cups and could be attached via zip ties to the sides of the shelving units,
Video was discovered that show instructors fabricating the racks and talking about the
number needed by Hildebrandt. It was originally believed by Roberts that a total of 12 to
16 racks were built, During the search warrant, I searched for the shelving units and
stainless steel racks. They were located in 2 horse trailer on the Hildebrandt property aud a
total of 5 shelves and 9 racks, were photographed. Based om the numbers found in the horse
trailer, I had Roberts secure a cost for producing them. The cost breakdown is listed
below:
Stainless Stee] Racks Metal Shelving Units ( per Lowes receipts )
Materials - $549.00 Materials - $1751.15
Labor _ $11,400.00 Labor - $4560.00Page #11 ( Flildebrande )
Interviews also produced information that school funds were used to purchase epoxy paint
that was later used to paint the three car garage at the Hildebrandt residence. Keith Moore
explained that he refinished the floor of the Lively construction department with a beige
epoxy coating and Hildebrandt liked the completed project. He therefore told Maore to
purchase additional epoxy in the same color and paint the floor of his three car garage.
Sherwin Williams receipts verify that a lerge quantity was ordered on a Lively account in
July of 2012. [ also located a receipt dated August 2012 for a smaller amount which
matches Moore's sworn statement, I alse responded to the construction department and
took photographs of the finished ficor. During the search warrant, I examined the garage
floor and found that it had the same type of finish and color as the floor at lively. The floor
was photographed and I took a sample of the paint as evidence. Based on the sworn
statement by Keith Moore, the receipts from Sherwin Williams that match his statement
and my observations at the Hildebrandt home, it appears that Hildebrandt used schoot
funds to purchase epoxy paint to finish his garage floor. [have listed the cost of the
Materials - $792.00
The next item discovered during my investigation involved a wooden window seat that was
built by Keith Moore in the construction department at lively. According to Moore,
Hil
Keith Moore responded to the Mahan Drive address and took measurements for the
project and then began work on the seat. Photographs were taken during several phases of
the build and the seat was taken to the Hildebrandt home upon completion. The seat was
instalied underneath a large window in the living room and it had lift up lids for interior
storage. I located the seat in the Hildebrandt home during the execution of the search
warrant and photographed were taken of the seat in its installed location ( livingroom
under a large window ).. Moore advised me that the total cost of the window seat was
approximately $500.00 which included materials and labor. He told me that the cedar
lining had to be special ordered because it was not something the school had in stock. While
photographing the window seat at the Hildebrandt home, I checked the interior of the seat
to determine if it had a cedar lined interior and could smell the cedar as I opened the top.
Moore explained that Hildebrands planned to store linens inside the seat and the cedar
would deter insects,
Materials and Labor - $500.00
itwas also brought to my attention during the above listed interviews that Hildebrandt
ordered three of his employees to adjust their timesheet with extra hours to secure funds to
pay Bailey Hildebrandt for his summer employment at Lively during the summer of 2011
and 2012. Keith Moore, Floyd Roberts and Melford Sims gave similar sworn statements
that Bailey worked at the school durizg those summers and they paid him from the padded
hours.Page # 12 ( Hildebrandt )
Ira Schal who was a student in the welding department also advised me during his sworn
statement that he remembered having conversations with Roberts and Sims ehout the
payments. Schul explained that the two instructors were upset they were being asked to
pad their hours to pay Bailey. It was explained that Bailey was not actually employed by
the school but did odd jobs at Lively during those summers and was seen working at the
school by instructors and students. Keith Moore told me that he paid bailey $10.00 per
hours which totaled $400.00 per week but he could not remember if Bailey worked a full 40
hours each week. He initially told me that he paid Bailey in cash but later revised it by
saying it was possible that he wrote him a check for some of the payments. I located several
checks written to Bailey Hildebrandt by Keith Moore during the summer of 2011 and two
withdrawals for $1350.00 during the suminer of 2012. Roberts and Sims told me that they
were required to pay Bailey $200.00 per week. Sims stated that he only paid Bailey for
three months in 2011 and did not continue the practice in 2012. Roberts stated that he pald
Bailey the entire summer of 2011 and one final payment of $600.00 in 2012. Roberts and
Sims believed that during 2011, they gave Bailey the full $800.00 per month for those three
months, Bank statements showed $800.00 cash withdrawals for Sims and Roberts in July
and September of 2011 which are consistent with their statements. I did not locate a
payment in August of 2011 fer either man. However, when asked about the August
payment, both men advised that it was possible that it could have been paid from a larger
withdrawal or money from a welding side job. Roberts could not remember row he paid
‘the $600.00 in the summer of 2012. He remembered a conversation with Bailey at the
school when the final $600.00 dollars was paid because he had grown fired of padding his
hours. He gave the money to Bailey and told him to tell his father that it was the last
payment and that he would not do this anymore. based on testimony from the instructors
and bank stamen information,, the following totals were secured:
Sims payments - $2400.00 ( 2011 ) $1600.00 verified via bank statements
Roberts payments ~ $2400.00 (2011) $2600.00 verified via bank statements
$600.00 (2012) unable to verify
Moore payments - $2340.00 ( 2011 ) checks verified via bank statements
$2700.06 (2012 ) verified via bank statements
A final theft allegations could not be definitively link to Hlildebrandt. The school ordered a
large quantity of rubber stall mats ( 150) for a ear show and approximately forty of the
mats were used. The remaining mats are no longer at the school and it is believed that the
mats were stolen, During my search warrant, I located approximately 128 mats on the floor
of the Hildebrandt horse stables. The mats are similar to those missing from the school but
appear to have a different ¢exture. I was therefore unable to determine if the mats in the
horse stable are the missing mats from Lively.