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    News 3 received the arrest report of Ralenkotter in September 2019

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    News 3 received the arrest report of Ralenkotter in September 2019

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    © All Rights Reserved
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    142 views27 pages

    Ralenkotter KSNV Arrest Report

    Uploaded by

    Phillip Moyer
    News 3 received the arrest report of Ralenkotter in September 2019

    Copyright:

    © All Rights Reserved
    Download as PDF or read online from Scribd
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    JUSTICE COURT, LAS VEGAS TOWNSHIP CLARK COUNTY, NEVADA State of Nevada Case No, 19F06007A. Plaintiff, vs. RALENKOTTER, ROSSI MOTION FOR DISCLOSURE OF NON-PUBLIC INFORMATION ) ) ) ) ) ) — Dept.No. 03 ) ) d d ) ) Defendant(s), ee DECLARATION (1) PLEASE CHECK ONE OF THE FOLLOWING OPTIONS: This Motion is being brought by: [+] A member of the following media organization: KSNV-TV [| The following criminal Defendant: [1 Anattorney for the following client: [1] OTHER: (2) PLEASE COMPLETE THE LINE BELOW: Court staff has indicated that the following document(s) currently in the file are deemed to be presumptively non-public and confidential: Arrest warrant (3) PLEASE EXPLAIN WHY THE COURT SHOULD ALLOW ACCESS TO THE, DOCUMENT(S) LISTED ABOVE : (NOTE: If you need more space, please attach additional pages.) ‘The case is of public interest. (4) PLEASE SIGN BELOW: Under the penalty of perjury under the law of the State of Nevada, I swear or affirm that the above information is true and correct, and that the Court should allow access to the requested document(s). Signature: EZ A _ Date: Sept. 10, 2019 Phone Number: (702) 657-3150 _ ORDER [ ] This matter will be set for hearing, and all parties will be notified. The hearing date will beat M onthe dayof_ » 20. [ ] The motion is denied as to the following documents: for the following reason(s) The motion is granted as to the following documents: Criminal Complaint CTemporary CustodyRecord ClDeclaration of Arrest Report Declaration of Warrant/Summons Clanest Warrant Abstract a a (approval for the above-specified documents is in their “as redacted” form) {] OTHER: SEP 20 2019 DATED THIS DAY OF 20. JUST) TH HARMONY LETIZIA {LAS VEQAS METROPOLITAN POLICE DEPARTMENT DECLARATION OF WARRANT/SUMMONS, FILE (N.R.S. 171.106) (N.R.S. 53 amended 7/13/1993) cpuy ser 9 P 218 Event Number: 1806191037 TE COURT, STATE OF NEVABAY?2)5.82 Br@Wvoodson _ 7 1 5080004 werobo70 county oF cLARK °§°*"' pos: Sst: Ueiaton of Ware Summon (don nn E, Mortis, being first duly sworn, deposes and says: J That He is a Detective with the Las Vegas Metropolitan Police Department, being so employed for a period of 11 years, assigned to investigate the crime(s) of Conspiracy to Commit Theft committed on or about 09/12/2012 - 01/19/2017, which investigation has developed Eric Woodson as the perpetrator thereof. ‘THAT DECLARANT DEVELOPED THE FOLLOWING FACTS IN THE COURSE OF THE INVESTIGATION OF SAID CRIME, Town: 1. Your Declarant is a Detective with the Las Vegas Metropolitan Police Department (LVMPD), currently assigned to the Criminal Intelligence Section. Your Dectarant has, in the past, participated in other investigations involving complex financial frauds and public corruption, 2 In April2018, the Las Vegas Review Journal (LVRJ) began to publish a series of news articles detailing the ‘misuse of public funds by members of the Las Vegas Convention and Visitors Authority (LVCVA). These articles were released ater the LVRJ conducted an investigation based on information they obtained through a Freedom ‘of information Act request. The LVRJ was able to make the request due to the fact that the LVCVA is an organization funded primarily with public monies and is considered @ public agency.’ The LVCVA describes itself as a governmental agency that was established by state law, is funded by county room tax and is governed by an autonomous board of directors. The content of the LVRJ articles ilustrated a ranking executive within the LVCVA, John *Brig’ Lawson, had discreetly purchased Southwest Airines (SWA) gift cards and dispersed them to other employees which were then used for personal travel. Rossi Ralenkotter, who was the Chief Executive Officer and President of the LVCVA at the time, and Lawrence | who was Chairman of the Board of Directors at the time, were named in the LVRJ article as having benefited from the secretly purchased SWA gift cards, The news piece reported Ralenkotter and jill! used the SWA gift cards for personal or non-business travel. The articles further went on to describe how Relenkotter kept a large amount of the SWA gift cards in his desk. * Las Vegas Convention and Visitors Authority Comprehensive Annual Financial Report 08/30/2018; Page 6 of the Finance section; page 26 overall tvwro 4 0 ORD 2010 LAS VEGAS METROPOLITAN POLICE DEPARTMENT CONTINUATION Event #: 180619-1037 3. Your Declarant obtained a publicly available Forensic Accounting Report completed by Eide Bailly LLC that detailed the following information; In January 2017, LVCVA Finance Group became aware of Lawson's inappropriate purchases of SWA gift cards. It was determined that Lawson would hide the purchasing of SWA gift cards in payment requisition forms that were authorized for other purchases such 2s sponsorships to SWA events. Lawson had authorization to purchase certain levels of sponsorships to annual events in order to boost tourism and travelto Las Vegas. Lawson used two methods to conceal the purchase of SWA gift cards; one method was to hide itt card orders within some of the legitimate purchases and the other was naming a purchase of SWA gift cards ‘something else altogether (completed with the assistance of an SWA employee responsible for fulfiling the order). A total of seven instances were found where Lawson used deception to hide the purchase of SWA giftcards. These purchases took place from 2012 to 2017 and totaled $90,000.00. Upon the discovery, the Finance Group took possession of the SWA gift cards purchased by Lawson and maintained control, tightly regulating who ray travel with funds associated with those SWA git cards. Complying with the records request put forth by the LVRJ, LVCVA General Counsel Luke | was tasked with collecting the documents for review and redacting protected, privileged and/or sensitive information. Upon review of the documents for redaction, | discovered Lawson's illegitmately purchased SWA git cards were being used by Ralenkotter for personal or non-business travel. When the personal or non-business travel was identified by | he discussed the issue with Ralenkotter and also brought it to the attention of LVCVA Chief Financial Officer Ed During the discussion with Ralenkotter, j told him the use of LVGVA purchased SWA gift ‘cards for personal or non-business travel was inappropriate and needed to stop. After j confronted him, Ralenkotter no longer used the SWA gift cards for personal travel and reportedly repaid what he had used to the Lvcva, Prior tothe discovery of these purchases, it was not uncommon for LVCVA employees to utilize the LVCVA, Travel Agency to book personal travel. It was generally accepted that employees could utlze the travel agency while paying for travel with personal finances for personal or non-business travel. The LVCVA Travel Agency is responsible for booking/paying for travel forall authorized business related travel. After the misuse was revealed, ‘ended the practice of employees using the LVCVA Travel Agency to book personal travel 4. After the discovery of personal or non-business related use of LVCVA purchased SWA gift cards, Conducted an internal audit of personal or non-business travel purchased by employees of the LVCVA, ‘audit was based primarily on information from LVCVA email communications he researched, had discovered significant and widespread abuse during his preliminary analysis. The analysis information was provided to Bil } who was the Chairman of the Audit Commitee for the LVCVA at the time. Once advised of the situation, | retained outside counsel Pisanell Bice, PLLC for a review. Shorty after the review, Pisanelli Bice, PLLC retained Eide Bailly LLP to conduct a forensic analysis ofthe practices associated with travel within the LVCVA and the use of LVCVA funds to pay for personal travel. Eide Bailly LLP conducted an audit utlizing documents that were provided by the LVCVA. In addition to physical documents, Eide Baily LLP was also granted access to the LVCVA Page 2.0119 LAS VEGAS METROPOLITAN POLICE DEPARTMENT CONTINUATION Event #: ___180619-1037 ‘email servers to examine communications regarding the purchase of SWA gift cards and their subsequent use, The Forensic Accounting Report dated 06/08/2018 details the process and findings ofthe audit. Forensic Accounting Report According to the Forensic Accounting Report, auditors were given access to LVCVA servers for the purposes of obtaining emails and other documents that would provide insight into abuses of LVCVA purchased ‘SWA gift cards. In addition to emails and documents, auditors were given documents deemed relevant during » preliminary audit. In total, the forensic analysis completed by Eide Bailly LLP showed Lawson had deceptively purchased $90,000.00 worth of gift cards from 2012 - 2017. The Forensic Accounting Report noted the ‘methods in which Lawson would conceal the purchase of SWA gift cards. Lawson would purchase SWA gift cards ‘along with sponsorships for SWA events and then inflate the cost while leaving any mention of git cards off of the invoice. Another method Lawson used was to simply name the purchase of SWA gift cards as SWA sponsorships (on the invoices provided by SWA. Lawson would direct SWA employees to label invoices differently, appearing to be an event sponsorship, although the full payment was for the SWA gift cards. Of the total amount of SWA gift cards, the analysis depicts $19,631.80 was used for personal or non-business travel with $19,979.81 used for legitimate LVCVA business travel. The Forensic Accounting Report stated Ralenkotter had used LVCVA purchased ‘SWA gif cards for personal or non-business travel. In addition to Ralenkotter, the report listed his wife, Mary Jo ‘as well as persons identified as ‘additional travelers’ and “Ralenkotter family members and office staff.” Specific names of persons associated with “additional travelers” and ‘Ralenkotter family members and office staff” were left out of the completed Forensic Accounting Report. The auditors did however break down when and where Ralenkotter and Mary Jo traveled using LVCVA purchased SWA gift cards for personal or non-business travel for ‘a total of $16,207.81. The Forensic Accounting Report says outside legal counsel reported to auditors Ralenkotter reimbursed all amounts identified as their responsibilty. 5. _ In June of 2018, coinciding with the release of the LVRJ news articles, your Declarant along with other detectives from the LVMPD Criminal intelligence Section began an investigation into crimes committed by ‘employees and executives with the LVCVA in regards to the SWA giftcard scandal. Based on the allegations made by the LVRJ and the apparent confirmation of criminal acts outlined in the Forensic Accounting Report, your Declarant did believe that an investigation into misconduct and theft was warranted. ‘On 06/28/2018, your Declarant along with Det. Stanton P#4717 and Senior Financial Intelligence Analyst (SFA) Haynes P#6160 met with isi to discuss the recent news articles and his knowledge of the SWA gift card ‘abuse. This meeting took piace in } office within the executive suites of the LVCVA (3160 Paradise Road, Las Vegas, NV, 89108). The meeting was voluntary and jit was not the subject of the investigation. requested the meeting take place at his office because he had a large amount of documents to give investigators. ‘Also present in this meeting was LVCVA General Counsel During the meeting, jit explained the allegations made in the news articles were true and Ralenkotter had in fact used LVCVA purchased SWA gift cards for personal or non-business trav j confirmed to investigators he became aware of the secret gift card Page 3of 19 . LAS VEGAS METROPOLITAN POLICE DEPARTMENT CONTINUATION Event #: 18069-1037 purchases and personal travel while reviewing documents to be released pursuant to the LVRJ records request, ¢ also explained that Lawson had purchased the SWA gift cards, as described in the Forensic Accounting Report, and gave them to Ralenkotter and possibly kept some for himself. Both iit and } admitted that prior to the discovery, there was zero accountability for the use of SWA gift cards when they were in the control of Ralenkotter or Lawson. explained that during his preliminary audit, he was told by one of the travel coordinators that Ralenkotter directed some of his airfare be booked using SWA gift cards and those particular ‘SWA gift cards were located in the top drawer of Ralenkotter's desk. Ralenkotter used at least one SWA gift card for a donation to a church named Saints Peter and Paul in the Lexington, Kentucky area. This donation included other items such as luggage, entertainment and a hotel stay. ‘While in the meeting, and } voluntarily gave a large amount of paperwork that included emails, receipts, payment requisition forms, memorandums and other documents related to the preliminary audit {had completed. In addition to the hard copy paper documents, //j//} provided digital documents which contained more email correspondence, LVCVA finance policy and more documents related to the preliminary audit. All of the information that was provided by jill was done so on his own accord, jit said “you can have these” and “nothing we are giving you hasn't already been given to the Review Journal." One of the documents that was siven to your Declarant was titled “To-From Lawson and Woodson" which contained 3,396 pages and showed email ‘communication between Lawson and Eric Woodson from July 2011 to June 2018, Woodson was identified as being an employee of SWA and frequent contact of Lawson when dealing with the airine for official purposes. The content cf the emails also showed that Lawson and Woodson had a personal friendship, often communicating about Personal matters and planning vacations together. During the conversation, remembered a holiday party in December 2016 where Ralenkotter gave gift baskets to al of the LVCVA executives. iif said one of the items in the gift basket was a $200.00 SWA gift card. hhad no reason to be suspicious of this gift as it was not uncommon for a CEO or president of a large: company to gift items lke this for special events. ‘admitted he did use the gift card that was given to him by Ralenkotter. Your Deciarant asked [iyijilt and | if they had discovered if anyone else had used LVCVA purchased SWA gift cards for personal travel. Both said they had intially suspected Chief Marketing Officer Cathy ‘Tull to have flown personal or non-business travel paid for with LVCVA purchased SWA gift cards. As best they ‘could remember, lit and } said Tull was on an offcial business trip to London, England with a layover in New York when she changed her itinerary. iif believed Tull had family in New York and the changed itinerary was for a longer layover. Initially this raised a red flag for wit and | but after speaking with Tull and reviewing travel documents, they determined there was no misuse for this particular purchase. The layover did not Increase the cost ofthe travel and as they saw it, there was no abuse of LVCVA funds. ‘also provided insight into the procedure utilized by Eide Bailly personnel during their audit ‘sald LVCVA complied with all of the auditor's requests by providing access to computer systems, employees and Page 4of 19 LAS VEGAS METROPOLITAN POLICE DEPARTMENT CONTINUATION Event #: 180619-1037 documents. During the audit process, several employees were interviewed. confirmed all requested Personnel were interviewed, however, none of the interviews were compelled by the LVCVA and were completely voluntary. Your Declarant was told when Lawson's interview took place he requested that Tull be present. Initially, your Declarant believed both Lawson and Tull were physically present for the interview, however; it was later discovered Lawson's interview was done by auditors over the phone and Tull was in the room with auditors, { told your Declarant he attempted to get records from SWA to better track the usage of funds According to jl the SWA employee he contacted told him no such records exist. jit also contacted an SWA information officer who declined to give any information, citing that it was private information. In a later discussion with il he clarified when the first call took place, he was speaking with the individual who helped Lawson obtain the cards in the first place. When this conversation took place, if was in the very beginnings of the investigation and had yet to discover the SWA gift cards were purchased with LVGVA funds. At this point, and 1 knew the LVCVA was in possession of SWA gift cards and Ralenkotter had used them for personal travel and Lawson's scheme had yet to be discovered, Lawson maintained he was given the gift cards by contacts at SWA. informed Tull he needed full accountabilty of how many SWA gift cards existed in the LVCVA's possession and how many total SWA gift cards were given to Lawson. Tull responded to by telling him not to contact anyone at SWA because, in her words, he would damage the great relationship LVCVA has with SWA if he began asking questions. Tull instead offered to open communication with SWA and put jit in contact with ‘someone who could answer his questions. jill told investigators that a short time later he was on a conference call wth Tull, Lawson and Woodson. During this call Tul old si} any questions he had could be answered by ‘Woodson. When asked about the origins of the gift cards, Woodson told ji} that he was given the SWA gift ‘cards by SWA corporate for marketing purposes. Woodson claimed he felt the LVCVA should have the SWA gift cards because of their strong business partnership history and he did so through Lawson. jill asked how many ‘cards were given to Lawson with Woodson responding he did not know. This all took place on the conference call with Lawson and Tull. In addition to the conference cal, iif told your Deciarant that Tull forbid Lawson from ‘speaking to anyone about the acquiring and use of SWA git cards in all other situations, Tul instructed Lawson to request she be present any time anyone asked him about the SWA gift cards. ‘When lili discovered the misuse, all SWA gift cards that were located were transferred over to the ccontrol of the finance department and tightly regulated. He did however confirm that the numbers in the audit were correct and there are a significant number of SWA gift cards that were stil unaccounted for. The LVCVA decided the lost cards were a moot point because the cost of the investigation into the whereabouts of the cards would ‘outweigh the worth of the missing cards themselves. The estimate of missing cards was thought to be approximately '$50,000.00, The LVCVA closed its investigation into the missing SWA gift cards citing financial interests. ‘While explaining some of the documents he provided, lili told investigators that he saw all of the SWA sift cards Lawson purchased were paid for by check and j review of documents revealed check payments for the previously mentioned SWA sponsorships. Initially, your Declarant believed jit said that these types of purchases are normally done via credit card and there would be no reason to use an LVGVA check. In a later Page 5 of 19 LAS VEGAS METROPOLITAN POLICE DEPARTMENT CONTINUATION Event #: 180619-1037 interview with ji) itwas clarified the LVCVA prefers to pay for items such as gift cards and sponsorships via credit card (due to certain benefits associated with spending on these cards) but if the organization selling an item to the LVCVA charged a credit card fee, the LVCVA would pay by check. Inthe LVCVA employee handbook provided by ji LVCVA policy specifies conduct regarding accepting gifts, ips and gratuities. “after repeated declinations, a client or quest insists in offering a gratuity, the employee ‘may accept the gratuity: place itn an envelope and mark the envelope withthe date, gratuity amount, and guests’ name and/or company, and forward to the supervisor. The supervisor will then forward itto the ERC treasurer.” 6 After receiving the information and documents from your Declarant analyzed the data from the documents as it related to the misuse of the SWA gift cards. Some key documents were identified in the review and are as follows: ‘+ An email dated 06/05/2012 between Lawson and Woodson showed communication regarding an event ‘sponsorship. In this email, Woodson explains “Green Passes" are provided as trade for sponsorships and there is no way to sell the passes. Woodson suggests that the LVCVA purchase SWA gift cards as the cards would “provide better value for the recipient.” This email looks like the first time the idea of purchasing ‘SWA aift cards was presented to Lawson and it should be noted it was from this point on the hidden gift ‘card purchases were made. The email also says there willbe two different points of contact at SWA for Lawson with Woodson saying any other joint activities would be managed through them. This statement ‘contradicts hundreds of later emails where Lawson and Woodson regularly conduct business with each other while representing their respective businesses. + Adifferent email, dated 06/10/2013, shows Lawson communicating with SWA employee Laura jit about ‘an event called the "Summer Travel Program.” This sting of emails begins with what appears to be a gift card purchase made by Lawson on behalf of the LVCVA. Lawson asks jill the language on the invoice ‘can be changed so the final invoice mentions nothing about gift cards. jl; specifically asks Lawson ithe prefers the invoice not mention git cards and Lawson confirmed he did not want the gift cards listed on the invoice. Several attachments were included on the email and show the original invoice as well as the final copy with no mention of gift cards. A receipt, Payment Requisition form and check stub indicate Lawson bought $12,000.00 worth of SWA git cards and hid the purchase under payment for “Summer Travel Program” ‘+ In another email chain beginning on 06/27/2014 between Lawson and an SWA employee named Callie j there was a discussion about sponsorship payment for an event called the “Wright Amendment Spirit Party.” In this series of emalis there was a conversation of LVCVA purchasing a "Premier Level” sponsorship for $50,000.00 (the actual cost of a Premier Level sponsorship) and Lawson requested the invoice cost be increased to $73,000.00 with the balance of $23,000.00 being used for the “Green Passes.” Alater emailin this chain showss Lawson asking "Can you delete al of the payment information section and Just have the balance due line with the total amount of $73k?" Also contained in this email chain was an explanation that SWA could not include the Green Passes as they would technically be "sold" to the LVCVA Page 6 019 [LAS VEGAS METROPOLITAN POLICE DEPARTMENT CONTINUATION Event#: __ 180619-1037 which is prohibited. There is also a portion ofthe emails that show Lawson's concern over ij requesting ‘an LVCVA WS to complete the purchase.? The final invoice does not appear to show a purchase of gift cards of Green Passes which indicates Lawson terminated his transaction fearing that his scheme would have a more extensive paper trail with the addition of a W9, Although theré was no purchase of SWA gift cards or Green Passes, this email shows the process in which Lawson would mask the purchase of the SWA gift cards. + On another notable email chain, Lawson is communicating with Woodson and the subject line is titled “git cards.” Although there is not much information contained in the body of the emails, there is mention of an ‘invoice’ as well as attachments on some of the emails. In what appears to be the initial invoice, a description of items purchased notes “SWA GIFT CARDS/ 70 @ $200EA/ 20 @ $50 EA = $15,000" with the total amount at $15,000.00. This inital invoice looks to be on an official color SWA invoice. In the body of the email and subsequent replies, Woodson asks “Does the attached work? Or do you need specific ‘words added" with Lawson replying 'Nope...will email you.” It is unknown if a different email address was Used to conceal the nature of the conversation or Lawson's instructions, but in the next email Woodson offers a different invoice, this time with the description of items purchased saying “Wright Amendment Deck Event Sponsorship.” The wording in the description is crooked and off-center and appears hasty edited. ‘According to the time stamps on the email, approximately five minutes later, Woodson sends another email {o Lawson with the same invoice, however; this time the description section is straight and more centered than the last. Both follow-up invoices are in black and white print and appear slightly pixelated as if they were copied or scanned which would have happened ifthe original invoice was modified by Woodson or ther SWA employees: In all three documents, the dates, customer number and Invoice number are the ‘same with the only change being the description of what was purchased. This invoice amount correctly matches the receipts Lawson received on 06/17/2014 (order number 5810655 and 5810679). After further review of the documents provided, it appears when a Payment Requisition was submitted to pay for the SWA gift cards (under a sponsorship name), twas originated by Lawson and approved by personnel in positions above him with higher purchasing limits. On the requisition forms there is a signature line with the ttle “SR VICE PRES". In al cases where a Payment Requisition form was used to purchase SWA gift cards, Tull's name appears in SR VICE PRES area. There are five instances where Tull's name signed on the signature line of the document and three instances where someone signs on her behalf. Although signatures forthe three are ilegible, “Yor C. Tull" can clearly be seen after the name. These requisition forms suggest Lawson had the authority to make purchases and Tull was the approving executive. Your Declarant leamed later from seized emails that when an executive is unavailable, they wil designate an executive with the same purchasing power to sign on their behalf. Allof the Payment Requisition forms are accompanied by 2 copy of a check stub that reflects the payment amount ‘due. The following are check numbers by year where LVCVA purchased SWA gift cards through Lawson: 2 IRS form WA Is used to provide a correct Tax Identification Number to the person who is required to file an information return with the IRS to report, for example, income paid, real estate transactions, mortgage interest paid, acquisition or abandonment of secured property, cancellation of debt or contributions made to an IRA. Page 7 of 18 LAS VEGAS METROPOLITAN POLICE DEPARTMENT . CONTINUATION Event #. ___180619-1037 09/20/2012; Check # 86403; Bank of America; $10,000.00 07/03/2013; Check # 89538; Bank of America; $12,000.00 * 07/03/2014; Check # 94025; Bank of America; $18,000.00 * 03/08/2015; Check # 96627; Bank of America; $54,000.00 ‘+ 06/25/2015; Check # 97858; Bank of America; $15,000.00 ‘+ 02/11/2016; Check # 100443; Bank of America; $54,000.00 © 01/19/2017; Check # 104608; Bank of America; $67,000.00 ‘The purchases required Tul's approval based on the dollar amount of the purchases. Lawson did not have the purchasing power to approve these transactions, It is unknown to investigators why Tull would have epproved payment by check for these events without justifying the cost, Tull was either aware of the scheme, conspiring with Lawson to discreetly purchase the SWA gift cards or sponsorship payments were commonly initiated by Lawson and Tull simply approved the payment unaware Lawson inflated the price. The latter is unlikely based on what was learned about the conference call between Tull, Lawson, Woodson and ji} as previously mentioned. ‘Another provided document is labeled “Gift Card Acct’ which contained a collection of emalled receipts for flights purchased through the LVCVA Travel Agency. Each receipt showed fight information including confirmation number, date of travel, name of passenger(s) 2s well as the cost associated with the fight and how it was paid for. In the payment section of the receipts there was a breakdown of SWA specifc git card numbers as well a5 cost ‘associated with that card and any applicable credit card payment. For the purposes of this declaration, the SWA gift card numbers found on the LVCVA receipts will be referred to as “known SWA gift cards." All other cards that Were purchased and not listed in the receipts will be referred to as “unaccounted for SWA gift cards." ‘According to research, a total of 610 SWA gift cards were purchased by Lawson for a total of '$90,000.00. These purchases were made between 09/12/2012 and 02/02/2017, 7. On 08/13/2018 your Declarant obtained a Grand Jury Subpoena for information and documents related to the forensic analysis completed by Eide Bailly, LLP. The Subpoena was delivered to the managing partner of the Las Vegas Eide Bailly office on 08/16/2018, (On 09/10/2018 your Declarant met with a representative from Eide Bailly who provided the subpoenaed documents on a portable hard drive. The files on the hard drive included the folowing folders: ‘= Documents Received from Client + Eide Bailly Contact Information + Eide Bailly Emails + Interview Notes, + LVCVA Email Production Page 8 of 19 {LAS VEGAS METROPOLITAN POLICE DEPARTMENT CONTINUATION Event# __ 180619-1037 * Reports and Exhibits ‘Most ofthe provided information was redundant as the emails were generally duplicated when certain send features were utlized (.e, CC, fwd, multiple recipients, etc.), however; the emails did provide information regarding the purchase of some of the SWA gift cards and who used them. in one of the folders, a document was discovered that showed emailed receipts for travel dating back to 2012. These receipts included confirmation number, ticket ‘number, destination locations (return trips when applicable), name of passenger(s) and payment information. All of the receipts in this document contained git cards purchased travel and it appears that business and personal travel ingled when listed. In a folder titled "Eide Bailly Emails’, various spreadsheets document the SWA gift card usage. It was later determined that a majority of these spreadsheets were “works in progress" and did not Contain all ofthe information used in the final Forensic Accounting Report. Some documents provided by Eide Bailly

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