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STATE OF CONNECTICUT DISPOSITION DATE


SUPERIOR COURT

DEFENDANT ADVISED OF RIGHTS BEFORE PLEA ELECTION

(JUDGE)

o ATTORNEY U PUB. DEFENDER I GUARDIAN


(D,t>,TE)
BOND CHANGE
OCT 0 JY
SEIZED PROP. INVENTORY NO.

PLEA WITHDRAWN I VERDICT


COUi)iT PLEA DATE FINE REMIT ADDITlb':'AL DISPOSITION
DATE I NEW PLEA i FINDING

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APPLICATION
IF PAID FEE - RECEIPT NO. : CIRCLE
W IONEQ I IF
PROGRAM
PAID FEE - RECEIPT NO. : elRe.
W LE I o.NE
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IF PAID Tio.N FEE - RECEIPT NO.. :' CIRCLE
W IONEQ

STATE'S ATTORNEY ON ORIGINAL DISPOSITION I REPORTER/MONiTOR ON ORIG-:-OISP. -rSIGNED (Cierk) I SIGNED (Judge)
iNFORMATION STATE OF CONi-.JECTiCUT
JD-CR-71 Rev. 1-03 SUPERiOR COURT·

_Ii'
GA N°'IDATE .
I 0\ !2<a! ~. f/- _ .. I 57"....
ATE OF CONNECTICUT
fO: Any Proper OffIcer or tne State of Connecticut .
By A.UTHORiTY OF THE STATE OF CONNECTICUT, you are hereby commanded to arrest the body or the within··named
accused. {')(" aff that BPP/V)

o A.. Accused is orderedtb be brought before a clerk or assistant clerk of the Superior CourL
o B. ,f"ccused isnotentitlt3dto bail. .
If A, B or both are checked above, you shail without undue delay bring the arrested person bef()re the derk
or assistant clerk oftheSuperior Court for the geographical area where the offense is ~Ile'ged to have been
committed, or if the clerk's office is not open, to a community correctional center witbipsqid geographical
area, or the nearest community correctional center if no suchcenter exists in the geqgr?phicCllarea, or to
the Correctional Institution, as the case may be. IEXTRADITION BOUNDARIES ESTABLISHEDBY PROSECUTOR
n C. Bail set at
, ~ Conditions.Of release not determined by court.

Th~n~i1~there, bxvi1ue9.ft~e\Vitrin and foregoing complaint and warrant, i arrested the body of the within-named accused and read the
sameihthe
ATTEST (Offlcer's signature and Department)
-----------------------------------~
hearing Of said accused; and have said accused here in court for examination.

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JD·CR-71 (back of page 1) Rev. 1-03


o SEE ADDITIONAL PAGE(S)
ARREST WA,.RRANT APPLICATION STATE OF CONNECTICUT FOR COliRT lISE ONLY
JD-CR-64EL Rev.10-04-
C.G.S. § 54-2a. SUPERIOR COURT
Pro Bk. Sec. 36-1. 36-2. 36-3 Supporting Affidavits Sealed
www.jud.state.ct.us
DYES 0 NO

AGENCY NO.

PI07-007
NAME AND RESIDENCE (Town) OF ACCUSED L.UUK I I U ,,~ HELD AT (Town) GANO.

Eddie PEREZ 59 Bloomfield Avenue, Hartford, CT Hartford 14


APPLICATION FOR ARREST WARRANT
TO: A Judge of the Superior Court

The undersigned hereby applies for a warrant for the arrest of the above named accused on the basis of the facts se1
forth in the ... x AFFIDAVIT BELOW.-- AFFIDAVIT(S) ATTACHED.

DATE AND TYPE/PRINT NAME OF PROSECUTING AUTHORITY

SIGNATURE S.A.S.A. Christopher Alexy


AFltlD'AVIT
The undersigned, being duly sworn, deposes and says:

THAT the undersigned affiant, Inspector Michael Sullivan, is a sworn member of State of Connecticut Division of
Criminal Justice, assigned to the Public Integrity Bureau in the Office of the Chief State's Attorney, having more than
twenty- five (25) years experience in the field of law enforcement and criminal investigation. At all times mentioned
herein, the undersigned was acting in his official capacity as a member of the aforementioned agency.

THAT on 02/03/2007 an article appeared in the Hartford Courant alleging cOlTuption in the administration of City 0
Hartford Mayor Eddie Perez. On 02/16/2007 the Office of the Chief State's Attomey began an investigation into the
allegations printed by the Hartford Courant.

THAT on 10/24/2007 a Grand Jury was empaneled in accordance with the COlmecticut General Statutes § 54-
47d(a). The focus of the investigation was ordered as follows: "To focus on corruption and the misuse ofpublicfunds
in the government of the Ci~)iof Hartford in its activities and dealings 'with persons or firms doing business with the
city." The Honorable Dennis G. Eveleigh was appointed Grand Juror.

THAT the Grand Jury investigation and the investigation by the Office of the Chief State's Attorney disclosed the
following:

THAT Eddie Perez is the Mayor of Hartford. He was elected to that position initially in 2001. He was reelected in
2003 and again in 2,007.

THAT on 06/26/2007 Inspector Sullivan received a telephone call from a source who stated that Mayor Perez had
remodeling work done to his kitchen by USA Contractors, Inc. The source infonned Inspector Sullivan that USA

(This is page 1 of 25 Page Affidavit)


DATE AND I DATE SIGNECiIAffianl)
SIGNATURE
Inspector Michael Sullivan .-2.?r
SIGNED (Judge! C_~k. Cqmr. Sup. Ct.. Notary Public
JURAT .... .:;.·-,:<1: ~~_.;-~}tir-'-- id...·~·,···l:~-,~
FINDING

The foregoing Application for and arrest warrant, and affidavit(s) attached to said Application, having been submitted to
and considered by the undersigned, the undersigned finds from said affidavit(s) that there is probable cause to believe that an
offense has been committed and that the accused committed it and, therefore, that probable cause exists for the issuance of a
warrant for the arrest of the above-named accused.

SIGNED '
AT (City or Town)
;,{-' ,
r~{i(\~rl.t
NAME OF JUDGE!JUOO£-'fR!Ab-R"l'~.&-~
DATE AND A/'-i l'\A.'\ vc..w,:?!""
r~J. '_.l. -,
-.-.-".,'"
SIGNED
t\ •• tt .'"
."a.t..,:'.,(Judge!
.•••.•.
ON (Date)
f~.. ~,
."...,.,..,"...,.
Judid8Trlii
.••.~~'-
e_K~.
f k:.../(t;{
Referee) {rif"j
ARREST WARRANT AFFIDAVIT INSTRUCTIONS STATE OF CONNECTIC,U:r
CONTINUATION PAGE The jurat is to be completed for each page of the affidavit. S.UPER,IORCOURT
JD-CR-64a Rev 10-04 The prosecutorial official and judge/judge trial referee are to date
C.G.S.§ 54-2.3 and sign or initial each page to indicate that they have reviewed it.:
Pro Bk. Sec. 35-1, 36-2, 36-3

NAME AND RESIDENCE (Town) OF ACCUSED


Eddie PEREZ 59 Bloomfield Avenue, Hartford, CT COURT TOHartford 14NO.
BE HELD AT (Town) /G. A.

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

Contractors has contracts with the City of Hartford for significant sums of money.

THAT on 06/27/2007 Mayor Perez was interviewed by Inspectors Michael Sullivan and Douglas Jowett in his offiCe
During the interview Mayor Perez was asked if USA Contractors did any work at his residence. Mayor Perez acknowledge
that USA Contractors does business with the City of Hartford. Mayor Perez stated that USA Contractors did his (Mayo
Perez's) bathroom vanities and countertops. Mayor Perez stated he paid $20,000.00 for the work and did not remembe
•• if any building permits had been obtained. Mayor Perez stated he paid USA Contractors by check about a year and a hal
ago [from 06/27/2007]. Mayor Perez stated that the $20,000.00 cost was "market price. " Mayor Perez indicated he woull
provide Inspectors Sullivan and Jowett with the cancelled check. Mayor Perez stated he did not have a written contract 0
any invoices and that it was "all verbal. "

THA T USA Contractors is owned and operated by Carlos Costa. Mayor Perez stated in his interview that Carlos Cost:
was a ''friend'' of his.

THAT in the interview Mayor Perez stated he became aware that the Haliford Courant was investigating cOlTuption il
his administration about 3 or 4 weeks before the first article was published. This would have been in the first week or sc
of January 2007.

THAT the 06/27/2007 interview with Mayor Perez ended approximately 12:30pm. When the interview ended Mayo
Perez indicated he was leaving to have lunch with his wife, Maria Perez.

THAT on 07/02/2007 Inspector Sullivan called Mayor Perez to inquire about the cancelled check that Mayor Perez hac
agreed to provide. A message was left with Mayor Perez's secretary, Barbara Crockett. A short time later InspectOl
Sullivan received a telephone call from Attorney Hubeli Santos. Santos indicated he represented Mayor Perez. InspectOl
Sullivan inquired about the cancelled check that Mayor Perez had previously agreed to provide and asked if Mayor Pere2
was going to provide it. Santos indicated he would have to speak with Mayor Perez before answering.

THAT on 07/06/2007 Attorney Santos came to the Office of the Chief State's Attorney with Attoiney Hope Seeley. A
meeting took place between the two attorneys, Chief State' s Attorney Kevin Kane, Supervisory State's Attorney ChIistopher
Alexy, and Inspector Michael Sullivan. Santos indicated that he represented Mayor Perez. Santos stated that Mayor Perez
had not paid the bill associated with the renovation work done by USA Contractors at the Perez residence. Santos stated
that Mayor Perez would be paying that bill ShOlily. Santos stated that an invoice for the work did exist. Santos agreed to
provide the renovation work documents to Inspector Sullivan.

THAT on 07/10/2007 Santos turned over-the documents to the Office of the Chief State's Attorney. On 07/11/2007
I:nspector Sullivan contacted Santos a11dinquired ifthe records received were representative of Perez's home renovations

:This is page 2 of a 25 Page Affidavit.)


DATE AND IDATE SIGNED (Affiant)
SIGNATURE / -/$ -0 Inspector Michael SullivanJ~../. ",.¢~

JURAT SUBSCRIBED ANDSW9R.1':!TO ~tFORE ME ON (Date) SIGNED (Jud~;be3<, Comm. Sup. C,J.,Nota';-yPU~)
s/' ",;~.,,/ ,<} ~-' i:-' f p,c,-?;;~~;;l- ~:~,,;:;~t"'l.! '~.
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REV(EWEp'(Pr9ie~ytori,af Official) REVIE;.WED/(Judg,SljJudge Trail Referee
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' ',/-- .(,/-: /' ··?1~'·
C.__ ,.•.. J'
"-~-~
ARRESTWARRANT AFFIDAVIT INSTRUCTIONS STATE OF CONNECTICUT
CONrlNUATiON PAGE The jurat is to be completed for each page of the affidavit. SUPERIOR COURT
,JD-CR-64a Rev. 10-04 The prosecutorial official and judge/judge trial referee are to date
and sign or initial each page to indicate that they have revievved it.;
Pro Bk. Sec. 35-1,36-2,36-3

NAME AND RESIDENCE (Town) OF ACCUSED


Eddie PEREZ '59 Bloomfield Avenue, Hartford, CT COURT TO Hartford
BE HELD AT (Town) 14NO.
IG. A.

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

done by USA Contractors. Santos acknowledged that they were.

THATAttomey Santos provided the Office ofthe Chief State's Attomeywith a bill from USA Contractors, Inc. mad
out to Eddie and Maria Perez dated February 28,2007. The bill states, "Please review this bill for all work completed (
59 Bloomfield Avenue. " The bill had numerous invoices attached to it and listed the following summary:

Kitchen Countertop 2385.00


1 BathTOom cabinst 371.00
1 Shower door 1774.63
1 Tile installation 750.00
1 Tile materials 1234.80
1 Grout & miscellaneous 88.21
1 Home Depot 1681.68
1 Metcaf Glass 408.02
1 Plimpton & Hills 5,762.47
1 Donald Sullivan' 2,862.00
1 Lump sum labor 2,900.00
Overall Total 20,217.00

THAT also included in the documents supplied by Santos were documents indicating that Mayor Perez obtained a secone
mortgage from the Hartford Federal Credit Union. Examination ofthe bill described above found that tax is not a separatt
entry on the bill. This is unusual as tax would have to be broken apart from the rest ofthe bill in order for USA Contracton
to pass the tax onto the govemment.

THAT inquiry was made with the Hartford Federal Credit Union. It was leamed that on 06/27/2007 Mayor Perez wen
to the Hariford Federal Credit Union at 2:08pm. Mayor Perez met with a credit union representative at 2:09pm for a home
equity loan application. This was less than two hours after the interview with Inspector Sullivan ended.

THAT on 06/27/2007 Mayor Perez and his wife, Maria Perez, applied for a $25,000.00 home equity loan to "pay fm
hOJne improvement Clndconsolidation of present debts. " The loan was approved and the loan proceeds, $25,000.00, wen
trans felTed to Mayor Perez's credit union account on 07/03/2007.

THAT on 07/11/2007 the Hariford Federal Credit Union printed an "official check" in the amount of$20,217.00 made
payabie-to DSA Contractors, Inc. This check was drawn on Mayor Perez's credit unIon account. The check was apparently
then sent to USA Contractors as payment for the renovation work at Mayor Perez's residence. The check was negotiated

(This is page 3 ora 25 Page Affidavit.)


DATE AND IDATE SIGNED (Affiant)
S lGNATURE 1-/3-0 Inspector Michael Sullivaf!Zi
SUBSCRIBED AND SWORN TO BEFORE ME ON (Date)
JURAT SIGNED(~;,~gel,:fl=". comm:?,ct., Notary P.
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RE yiEWJ!: [;i'Wrqs'ecutori pfOfficial ) DATE


REV.)EW,~DjJug.9g1 Judge Trail Referee
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ARREST w ARRAN1:AFftf)A\tJT~ lNSTRUCTIONS STATE OF CONNECTICUT
CONTINUATION PAGE The jurat is to be completed for each page of the affidavit. SJjPER!OR CO!iRT
JD-CR-64a Rev 10-04 The prosecutorial official and judge/judge trial referee are to date
C.GS § 54-2a and sign or initial each page to indicate that they have reviewed it.;
Pro Bk. Sec. 35-1, 36-2, 36-3

NAME AND RESIDENCE (Town) OF ACCUSED


Eddie PEREZ 59 Bloomfield Avenue, Hartford, CT COURT TO Hartford
BE HELD AT (Town) 14NO.
/G. A.

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

by USA Contractor's, Inc. on 07/13/2007.

THA T evidence showed that the work on the Perez residence was completed by August of 2005, however, the bill 0
$20,217.00 was not paid until July 11, 2007, almost two years later and only after Mayor Perez was confronted with th
infom1ation on 06/27/2007.

THAT Joaquim Espirito-Santo, who owns a business on Park Street, testified that he had learned about the renovatiol
work done at Mayor Perez's home from someone who worked at the house. Espirito-Santo stated he was told that buildin:
pem1its were not obtained for the work and that Mayor Perez was not going to pay for the work. Espirito-Santo stated h
told numerous people about this, including Minnie Gonzalez and Frank Banows. Both Banows and Gonzalez were mayora
candidates in 2007. Espirito-Santo said that he began complaining to anyone who would listen. He said he spoke tc
merchants in the Park Street area and even spoke about the renovations at public meetings.

THAT Inspector Sullivan examined Mayor Perez's cellular telephone records, Mayor Perez's appointment calendel
Mayor Perez's and his secretary's emails, I:1ayor Perez's office telephone, and Carlos Costa's telephone records. Numerou
telephone calls between Mayor Perez's telephones and Carlos Costa's were found throughout 2005-2007. Numerou
references to meetings between Costa and Mayor Perez were also found.

THAT Inspector Sullivan examined Mayor Perez's appointment calender for 06/27/2007. Numerous appointments ar,
noted throughout the day, including "Mayor's lunch wiMP" at 1:30pm. There is no reference to an appointment at th
Hartford Federal Credit Union.

THAT an investigation into the renovation project at the Mayor's home revealed that on February 20,2005, Eddie an<
Maria Perez went to the Home Depot in West Hartford and ordered new Corian counter tops to be installed in their kitchel
by Home Depot. They also purchase a stainless steel sink and a new faucet. The sink and faucet were taken by Mr. an(
Mrs. Perez, while they awaited the fabrication and installation of the counter tops. The total cost of the purchase wa
$4,071.10 and was paid for with a Visa credit card.

THAT on March 15,2005, the Home Depot file shows a "change order. n The change order indicates that the counte
tops were to be canceled and that $3,386.07 was to be refunded. (There are actually two revision copies (#1 & #2) becausl
the sales tax amount was adjusted). The double bowl sink and faucet were retained. The faucet was returned an<
reimbursed later.

THAT also included in the documents are copies ofthe "Purged Customer Orders Report. " These documents includl
abbreviated notes recorded from the Home Depot Associates. One notation dated March 16, 2005 states, "Per Karen, cus
called and said that she ,vas canceling b/c she got elsewhere cheaper, 1711.0711. for customer to call me back re: status. "

(This is page 4 of a 25 Page Affidavit.)


DATE AND I DATE SIGNED (Affiant)
SIGNATURE
Inspector Michael Sulliva.!1tu /-
SIGNED (Judge! Cler~, Comm. SUR- Ct., N~ry P
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REV)'EW~6 (p~1ecutorialpff~efal)
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AR:REST'WARRANT AFFIDAVIT INSTRUCTIONS STATE OF CONNECTICUT
CONTINUATiON PAGE The jurat is to be completed for each page of the affidavit. SUPERIOR COURT
,JD-CR-64a Rev. 10-04 The prosecutorial official and judge/judge trial referee are to date
C.G.S. §54-2a and sign or initial each page to indicilte thilt they have reviewed it.;
Pro Bk. Sec. 35-1, 36-2, 36-3

NAME AND RESIDENCE (Town) OF ACCUSED


Eddie PEREZ 59 Bloomfield Avenue, Hartford, CT COURT TO Hartford
BE HELD AT (Town) 14NO.
IG. A.

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

The next notation reads, "Spoke wi customer. She said she spoke wi David and he tried to price match competitors Coria.
and we could not. Said she is going to do the bathroom thru us but unfortunately we did not get the kitchen. Said Davi,
should hav cancelled. "

THAT on March 16,2005, the Home Depot file was closed out and the Perez VISA card was refunded $3,386.0;
Francisco Mmiinez, District Manager for Asset Protection, for the Home Depot later testified that it is extremely rare th3
~ Home Depot would allow a competitor to undercut a price for this type of purchase.

THAT over the next five months, Maria and Eddie Perez had their kitchen counter tops replaced with granite and tw<
upstairs bathrooms completely redesigned and renovated into one large bathroom. The work was completed by employee
of USA Contractors Inc.

THAT James Kopencey, Executive Director of the Hartford Parking Authority, testified that Carlos Costa, dba US)
Contractors, had several million dollars worth of contracts with the Hartford Parking Authority during the period 1998
2005. He indicated that the contracts consisted of both contracts acquired thTOughthe bid process and emergency repai
contracts, which were given without bid.

THA T there is no indication that Eddie and Maria Perez paid any kind of deposit for their renovations. The material:
and labor costs for the renovations apparently were absorbed by Carlos Costa and USA Contractors. The materials wen
paid for by USA Contractors during the construction. Testimony from witnesses indicated that it is unusual for an;
contractor to calTY that amount of liability for almost two years.

THA T Jeffrey Delgado, a former employee of Carlos Costa, testified that he worked at the Perez residence as ar
employee of Carlos Costa and then as an independent contractor, working for Mr. Costa. He testified about working or
the kitchen counter tops and doing most ofthe tile work in the bathroom. In addition Mr. Delgado testified about standarc
construction practice. He said that most contractors will get half of the cost up front. He said that sometimes a contractOl
will allow for payment to be made in thirds.

THAT one ofthe SuppOliing invoices in the bill package from Attomey Santos was an invoice from Jeffrey Delgado fOl
various work done at the Perez residence and the Carioca Club. There is a section ofthe bill that reads, "Work Pe110rmea
At: Church Street Garage." The words "Church Street Garage" appear to be an alteration to the bill. Also apparently
added to the bill are the codes "04149" and "03302." The amount ofthe bill is $2662.50.

THA T Jeffrey Delgado produced and testified to the original invoice that was still in his possession. Delgado testified
that he originally wrote "Carioca" and "Perez" in the Work Perf o1111 ed At section of the invoice. This was changed to
"Church Street Garage" sometime after Delgado gave the invoice to Carlos Costa. Delgado also inaicated the numbers

(This is page 5 of a 25 Page Affidavit.)


DATE AND IDATE SIGNED (Affiant)
SIGNATURE /-/3 -0 Inspector Michael Sullival]h
SUBSCRIBED AND SWORN TO BEFORE ME ON (Date)
SIGNED (Ju99,~Ci1J1' ~omm. S,Y.P-'Ct., N6tary ~iC)
JUFAT i-'/,'; . :,c t./ ~:.~<t,~· L,.~-·'····'·l. £r.
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R:~'::~1~,"~~~dge
f If / Judge Trail Referee
ARREST WARRANT AFFIDAVIT INSTRUCTIONS STATE OF CONNECTICUJ
CONTINUATION PAGE The jurat is to be completed for each page of the affidavit. S.UPERIORCO,!JRT
JD-CR-64a Rev 10-04 The prosecutorial official and judge/judge trial referee are to date
C.G.S. § 54-2a and sign or initial each page to indicate that they have reviewed it.;
Pro Bk. Sec. 35-1, 36-2, 36-3

NAME AND RESIDENCE (Town) OF ACCUSED


Eddie PEREZ 59 Bloomfield Avenue, Hartford, CT COURT TO Hartford
BE HELD AT (Town) 14NO.
IG. A.

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

"04149" and "03302" were added sometime after he submitted the invoice to Costa.

THAT Inspectors Sullivan and Keith McCurdy interviewed Carlos Costa on 08/14/2007. Costa acknowledged that h
was the one who altered the Delgado invoice as outlined above. Costa acknowledged that "04149" was the billing cod
USA Contractors used for the Church Str~et Parking Garage project. While it appears that the Delgado invoice was bille,
to the City of Hartford by USA Contractors, the investigation could not conclusively show that.

THAT upon examination of the USA Contractors invoice from Attorney Santos, it was found that there was work an
material that was not charged to Mr. and Mrs. Perez. The long marble bathroom vanity top (almost 9' long) is ne
accounted for at all in the billing. In checking with the two suppliers used by Carlos Costa, it was found that one slab 0
"Emperador Dark" marble measuring was ordered from EleMar Granite and Marble in New Haven on June 15, 2005. Th
order was faxed to EleMar Marble and Granite in New Haven from "Erica" at IMAGE Inc. which is the company tha
Carlos Costa was doing his granite work under. "Emperador Dark" was identified as the marble that was used in the Pere
bathroom. It also matches the tile that was ordered from IGM (International Granite and Marble Corporation) for the floOl
The order had an added notation, "Please send as soon as possible." The size of the slab that was ordered (106" x 61"
and the date ofthe delivery match up with the bathroom renovation. Earl C. Hanis, President ofElemar Granite and Marbl
testified as to the order and shipment ofthe Emperador Dark marble. The slab was billed out as 44.90 square feet @ 9.51
slf ($426.58). In addition to the cost ofthe raw material, there would have been fabrication costs including cutting sin]
holes, drilling faucet holes, and polishing.

TEAT Inspector Sullivan testified before the Grand Jury on 02/28/2008. Inspector Sullivan stated that on 07/10/200'
Inspector Richard Walsh and him were granted access to the interior ofthe Perez residence. Photographs were taken ofth
renovated upstairs bathroom. Inspector Sullivan measured the length onhe counter top in that bathroom. It measure,
approximately 105".

THA T inspection of the kitchen revealed that there is tile on the wall directly below the cabinets and above the bacl
splash, that is not accounted for. Jeffrey Delgado said that the tile was not in place when he installed the counter tops
There was no invoice for this tile work attached to the bill. In addition, there is no accounting for a custom made granit,
threshold that was installed between the dining room and kitchen. The threshold was made of the same granite as thl
kitchen counter top. Jeffrey Delgado testified about the fabrication ofthe threshold.

THAT Ramiro Morales was an employee of USA Contractors in 2005. Morales was assigned to do the electrical worl
required as pmi of the renovations in the Perez residence. Some of the electrical fixtures used in the bathroom are no
accounted for on the billing or receipts. RamiroMorales testified before the Grand Jury that he told Joe Nasciment(
(another USA Contractor's employee and Carlos Costa's brother-in-law) what he needed. He said that the material wa:
there for him the next day to install. It does not appear that all the electrical supplies are listed on the receipts that wen

(This is page 6 of a 25 Page Affidavit.)


DATE AND IDATE SIGNED (Affiant)
SIGNATURE /-/3-0 Inspector Michael SullivanJ.?1.:
SUBSCRIBED AND SWORN TO BEFORE ME ON (Date) SIGNED (JU9~/ Clerk, Comm. SUP,.Ct., Notary Pu
JURAT
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/' j:>v.-'"
- ARREST WARRANT AFFIDAVIT INSTRUCTIONS STATE OF CONNECTICUT
CONTINUAT.ION PAGE The jurat is to be completed for each page of the affidavit SUPERIOR COURT
JD-CR-64a Rev. 10-04 The prosecutorial official and judge/judge trial referee are to date
C.G.S. § ;i4-2a and sign or initial each page to indicate that they have reviewed it.;
Pro Bk. Sec. 3;)-1,36-2,36-3

NAME AND RESIDENCE (Town) OF ACCUSED


Eddie PEREZ 59 Bloomfield Avenue, Hartford, CT COURTTO Hartford
BE HELD AT (Town) IG. A14NO.

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

provided by Mayor Perez.

THAT in addition to the items that do not appear in the billing, the granite counter tops in the kitchen appear to b
underpriced. The counter tops are priced at $1000.00 cheaper than the Corian counter tops that were initially purchasel
from the Home Depot. The counter tops are priced at $45.00 a square foot (50 square feet.) There is no charge for tho
fabrication, ie ...cutting the sink hole and polishing. In addition, there is no billing for the 4" back splash that Mr. Delgad(
~ thought would add between $15.00- $20.00 per linear foot.

THA T the double bathroom vanity cabinet installed in the Perez bathroom as part of the renovation project was billec
at $350.00 (plus tax) for a total of $371.00. The vanity was custom made by Woodworks Retail & Architectural. Thi:
company manufactures high end cabinetry for commercial businesses and does a lot of business with Carlos Costa. Thi:
company is owned by Jolm and Richard Gajewski. A subpoena was later issued for all records relating to the cabinet. The
work file that was eventually turned over, details every aspect of the construction of the cabinet including a breakdown 0
man-hours. This included drafting, assembly and finishing. It took five workers in various departments - 21.25 hours tc
complete thisjob. The material cost was $158.40 and the cutting time was $41.96. During testimony, John Gajewski statec
that there was approximately $1200.00 worth oflabor to build this cabinet, not including the cost of material. Mr. Gajewsk
said that the cabinet was billed out for only $350.00 because Carlos Costa called them and said that he needed an invoice
for that price ($350.00). A cutting ticket located on the underside ofthe vanity shows that it was being constructed on Junc
16,2005. On January 04,2007, an invoice for the vanity was emailed to Carlos Costa in the amount of $371.00. USA
Contractors paid the $371.00 invoice with a USA Contractors check dated 04/13/2007.

THAT Jolm and Richard Gajewski also stated that they each donated $1000.00 to the re-election campaign of Mayor
Perez at the request of Carlos Costa. Neither Richard or Jolm Gajewski reside in the City of Hmiford. They testified that
they don't do business with the City of Hartford, and that their company is located in Bloomfield. Both ofthe brothers said
that they didn't attend the fund raiser event to which their donations are attributed to. They said that they made the
donations at the request of Carlos Costa. When asked what they would get from Carlos Costa for these concessions, John
Gajewski said, "011- time granite. "

THA T on March 17, 2005, bathroom plumbing fixtures and materials were ordered by USA Contractors from Plimpton
& Hills in Hmiford. The order was for $5,476.68. A deposit of $3,476.68 was paid by a USA Contractors' check. The
bathroom fixtures were ordered two days after the Home Depot order was canceled. Anthony Pellegrino, Director of Sales
for Plimpton & Hills, testified conceming the order and payments made by Carlos Costa's company.

THAT on March 17,2005, the shower stall was shipped from Plimpton & Hills (the one piece model would later be
exchanged for a two piece model in order to get it upstairs).

This is page 7 of a 2;) Page Affidavit)


DATE AND IDATE SIGNED (Affiant)
SIGNATURE Inspector Michael Sullivan..7u
SIGNED (Jud~,.(;le~5<' Comm. Sup. Ct., ~?rar~t~
t:;~t,·~i..~_.,.,,...~v.>"£.'
_~:.:/;? ,~.... J.-- ...-"- :

DATE
RE\(IEWE6(Pr9~fi~utofjal
. 'r. ( ... o,fficial)
! ~~
/-~!
../-;:: ! .
--." ( __._/.I i .._ .. c__
. ·t.-.-/ ,<) !()qr
ARREST WARRANT AFFIDAVIT INSTRUCTIONS STATE OF CONN6CTIC.U:r
CONTINUATION PAGE The jurat is to be completed for each page of the affidavit. SUPERIOR COURT
JD-CR-64a Rev 10-04 The prosecutorial official and judge/judge trial referee are to date
C.G.S. § 54-2a and sign or initial each page to indicate that they have reviewed it;
Pro Bk. Sec. 35-1, 36-2, 36-3

NAME AND RESIDENCE (Town) OF ACCUSED


Eddie PEREZ 59 Bloomfield Avenue, Hartford, CT COURT TO Hartford
BE HELD AT (Town) 14NO.
IG. A.

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

THAT the plumbing work on the Perez bathroom was done by Donald Sullivan and Sons Plumbing. This company alsl
has contracts with the City of Hartford. On January 17,2006, an invoice from Donald Sullivan & Sons Plumbing was ser:
to USA Contractors for $2862.00. On May 12,2006, USA Contractors sent check #14179 in the amount of$2,862.00 t,
Sullivan & Sons. In testimony, Arthur Sullivan stated that he also donated $1000.00 to the Perez re-election campaign a
the request of Carlos Costa.

THAT on April 12, 2005, the kitchen faucet purchased by Eddie and Maria Perez was retumed and refunded at the Hom
Depot.

THAT on April 12, 2005, two slabs of Juparana Bordeaux granite were ordered by USA Contractors from IGt'v
(Intemational Granite and Marble Corporation) in Windsor. IGM is one of two main suppliers used by Carlos Costa
Testimony identified the granite as the same type that was used in the Perez kitchen. The cost of the raw material wa:
$1993.86. The counter top is billed to Perez for $2385.00 - 50 square feet @ $45.00 square foot It appears a 6% tax 0
$135.00 is added to equal $2385.00. Testimony indicated this price is low.

THAT on 02/26/2008 Jolm Haberlin testified before the Grand Jury. Haberlin is the Northeast Regional Manager 0
International Granite and Marble Corp. Haberlin produced copies ofthe USA Contractors checks used by Carlos Costa tc
pay Intemational Granite and Marble Corp. for the Juparana Bordeaux granite described in the preceding paragraph
Haberlin stated that this type of granite is typically priced to a homeowner at $65-$75 a square foot

THAT Jose Nascimento testified before the Grand Jury on 02/28/2008. Nascimento is a full time USA Contracton
employee and the brother-in-law of Carlos Costa. Nascimento oversaw the Perez residence renovation project on behal1
of Carlos Costa. Nascimento stated he received his instructions from Costa on what work was to be done at the residence
Nascimento then instructed the various trades workers what to do. Nascimento stated he purchased the Home Dep01
supplies with either a USA Contractors credit card or his own credit card and was reimbursed for those expenses by Costa.
One of the items listed on the Home Depot receipts that was purchased by Nascimento was an 8000 btu air conditionel
($157.00 + tax). Nascimento stated the air conditioner was left at the Perez residence when the renovation project wm
completed.

THAT USA Contractors employees Roberto Moura, Jeffrey Delgado, Antonio Mouta, Jose Nascimento, Victor Costa,
Wilson Rodriguez, Luis Ribeiro, and Ramiro Morales-Flores testified about their roles in the renovation work. Several of
the workers said that this was the first time that they were asked to do this type of work for Carlos Costa and that he never
did home renovation work. The workers also spoke about painting, which not only included the new bathroom but, also
included the hallway and the downstairs bathroom. The individual workers could not be specific with dates, however, the
Home Depot receipts that were provided for the job, seem to give a chronology of how the work progressed. The documents
used were part of the package provided to investigators by Attomey Santos.

(This is page 8 of a 25 Page Affidavit.)


DATE AND I DATE SIGNED (Affiant)
SIGNATURE
Inspector Michael SUllivan~~/,~
JURAT SIGNED (~.~~~e'7c.17rk:comm:.,~~'_ ~t., Notary Pu
>/-:"~,../ :•.;,./,? / l. ..'~'
••.... .>

REV)iw~6 y.. (pr9s~cuJ~ri~tc;,ffiCial) DATE, . / ._.


REVIEW7:'::~;¥.:.~~_L:;I..~.9ge Trail Referee
l ?;l () f f 2,1."1/ () "1
-ARREST WARRANT AFFIDAVIT INSTRUCTIONS STATE OF CONNECTICUT
CONTJNUATI,ON PAGE The jurat is to be completed for each page of the affidavit. SUPERIOR COURT
JD-CR-64a Rev. 10-04 The prosecutorial official and judge/judge trial referee are to date
C.G.S. § 54-2a and sign or initial each page to indicate that they have reviewed it.;
Pro Bk:'Sec. 35-1. 36-2, 36-3

NAME AND RESIDENCE (Town) OF ACCUSED


Eddie PEREZ 59 Bloomfield Avenue, Hartford, CT COURT TO Hartford
BE HELD AT (Town) 14NO.
IG. A.

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

THAT on May 02,2005, a Home Depot receipt for $64.24 was for the following items:
2-stretch reach refill roller for paint
2- Mini reacher 12" handle roller for paint
2- 1 Y2" extra large paint brush
2- 2 inch extra large trim paint brush
4- 9" disposable paint tray

THAT on May 03, 2005, the shower door from Plimpton & Hills was canceled for $683.43. A custom door with (
transom is later purchased so the shower unit could be used as a steam unit.

THA T on May 03, 2005, the shower stall accessory kit and drain were returned to Plimpton & Hills for a $912.70 credit

THAT a Home Depot receipt for $30.61, dated May 03,2005, was attached to the bill. It was found to be for the
following:
3/4 inch 4'x8' Sanded Pine Plywood

THAT on May 06,2005, the plumbing supplies (toilet, sinks, etc...) were shipped from Plimpton & Hills.

THAT a Home Depot receipt for $29.86, dated May 06,2005, was found to be for the following:
60 yard 11 mil duct tape
5 pack ultra cover 6 inch paint roller
12 pack 6 inch fabric cover roller paint
2- metal roller frames

THAT on May 09,2005, the 5' Whirlpool tub was exchanged for a 6' Whirlpool tub. A difference of$285.79 was paid
by Carlos Costa on his MasterCard.

THA T a Home Depot receipt for $55.89, dated May 09,2005, was found to be for the following:
Sheet Rock/ Joint Compound for drywall
250 ft. Roll of joint tape for drywall
20-2'x3'-8 ft. spruce stud lumber

THAT a Home Depot receipt for $105.13, dated May 09, 2005, was found to be for the following:
10-1/4" 2'x 4' aspen hardwood plywood .
10- 2"x 6"·8 ft. #2 Douglas fir lumber
3- 2"x 3"_ 8 ft. pine stud lumber

9 of a 25 Page
This is page Affidavit.)
DATE AND I DATE SIGNED (Affiant)
SIGNATURE
1-/3 -0 Inspector Michael SUllivan..7u?"A"p
SUBSCRIBED AND SWORN TQ BEFORE ME ON (Date)
SIGNED (J~gei CI~~~'EComm.~up. Ct., NQiary"liC)
I 7..-T-- -,------._ •.
/{:J L ft': ~,.::~:/
..~ ~~~::>t1 ) ..-'- :(~..- ~, ,&-I~,~" ~!
'--r..."

REviEWED !Prosecutoriaf Official)


REVIEW.§QjJt,!..~ge / Judge Trail Referee
~_.._----~(~.)
(._,.~?/·f~._~.( " ,.' 1t1
L....-;"j /'"......
~. -------
ARREST WARRANT AFFIDAVIT INSTRUCTIONS STATE OF CONNECTICUT
CONTINUATION PAGE The jurat is to be completed for each page of the affidavit. SUPERIOR COURT
JD-CR-64a Rev. 10-04 The prosecutorial official and judge/judge trial referee are to date
C-.-G.S. § 54-2a and sign or initial each page to indicate that they have reviev·;ed it.;
Pro Bk. Sec. 35-1, 36-2, 36-3

NAME AND RESIDENCE (Town) OF ACCUSED


Eddie PEREZ 59 Bloomfield Avenue, Hartford, CT COURT TO Hartford
BE HELD AT (Town) 14NO.
IG. A.

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

2- 12" 4'x 8' sheet rockl drywall


1-114" coarse drywall screw SIbs. box

THAT a Home Depot receipt, dated May 12,2005, for $105.87 was found to be for the following:
GFCI outlet 3 pack white
20 amp 125 volt plug
5- 3/8" lockbox connector electrical
2- 15 amp. 120 volt grounded light switch white
2- flat bracket for metal box electrical
3- 4 inch metal octagon box electrical
4 inch j brackets for octagon box electrical
2- 3/4" xl/2" concrete tuck pointer with soft handle

THAT a Home Depot receipt, dated May 13, 2005, for $56.38 was found to be for the following:
12/3 25 ft. light cable flexible conduit
2- 35 pack anti short bushings electrical connectors
2- 318" lockbox connectors electrical
cable connectors 3 pack
square metal box with bracket electrical
3- 4 inch square metal box electrical
2 inch metal box with bracket electrical
3- 3"x2" metal gang box electrical

THAT a Home Depot receipt, dated May 23,2005, for $48.44 was found to be for the following:
9"x II" 150 grit sand paper
2-dimmer and light switch combo ivory wall plate
GFCloutlet
Stainless 60 minute timer
3 way almond light switch
4- metal 3"x 2" Light switch box
Scotch commercial grade electrical tape

THAT a Home Depot receipt, dated May 23,2005, for $176.36 was found to be for the following:
15- l"x2"x8" spruce lumber
12- 12" 4'x 8' drYlvall
IS" R-13 Insulation Mini ro 11

(This is page 10 of a 25 Page Affidavit.)


DATE AND I DATE SIGNED (Affiant)
SIGNATURE
----------------- 1-/3-09'. Inspector Michael Sulliva'lTu-
SIGNED (Jud~;t1.furk,
. ~
9:,\Tlm SUP/C.r, No ary P
JURAT / SUBSCRIBED AND S':"?RN
.} ...-.~. ,
TO<ElEFORE ME ON (Date)
f ./'''..:-;/';-",
~:~:if/'~'~t,,-.~;," ~,~ ~ ..-,t.
REVIEWED (Judge / Judge Trail Referee
REVI Ev{E~«P:Os~cutoria( bffjcial)
..•.•.•...._ ,if', .~.,.j '....
" /'--::{..--i .--'~
~7ij '-""" .
ABgEST, WARRANT AFFIDAVIT INSTRUCTIONS STATE OF CONNECTICUT
CONTINUAT.ION PAGE The jurat is to be completed for each page of the affidavit. SUPERIOR COURT
JD-CR-64a Rev. 10-04 The prosecutorial official and judge/judge trial referee are to date
eG.s. § 54-2a and sign or initial each page to indicate that they have reviewed it.;
Pro Elk. Sec. 35-1, 36-2, 36-3

NAME AND RESIDENCE (Town) OF ACCUSED


Eddie PEREZ 59 Bloomfield Avenue, Hartford, CT COURT TO Hartford
BE HELD AT (Town) 14NO.
IG. A.

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

1-5/8" Coarse Drywall Screw 5 lbs. box


6 pack pocket rags
Polyurethane Satin Quart
10 count select latex gloves
wood finish cherry stain
wood finish natural pine stain
~ 1" performance select silver flat paint brush
Extra heavy duty knife blade

THAT a Home Depot receipt, dated May 24,2005, for $47.09, was found to be for the following:
3 - unknown item
300 ft. roll of joint tape for drywall
White Home Depot Cotton Apron
5 pack Reciprocating Bladed for Skill saw
10 inch soft handle taping knife for drywall
6 inch soft handle drywall utility jab saw.
6 inch hammer-end lmife stainless steel for drywall

THAT a Home Depot receipt, dated May 06, 2005, for $16.24, was found to be for the following:
6- 1 1/4" x 8 ft. comer bead for drywall
1 12" galvanized roofing nail 1 lb box
1 1/4" galvanized roofing nail 1 lb box

THAT a Home Depot receipt, dated June 06, 2005, for $138.49, was found to be for the following:
1 1/4" x lOft comer bead for drywall
1 1/4" coarse drywall screws 5 lbs. box
Wallpaper stripper remover- gallon
5- 12" 4'x 8' sanded pine plywood
Do It Yourself Wood shims pack
1 3/8" Coated drywall nails 1 lb box
2- 3" white bristle brush for paint

THAT a Home Depot receipt, dated June 07, 2005, for $105.04, was found to be for the following:
Sheet rock/ Drywall J oint compound
10- 3 100 ft. roll electrical wire
2- 3/4" plastic staples

(This is page 11 of a 25 Page Affidavit.)


DATE AND IDATE
SIGNATURE
. __-0
SUBSCRIBED AND SWORN TO BEFORE ME ON (Date)
/i --I --, L'
REVIEWEQ(Pr6secwtorip'i Offjcial)
, :.',f.~' . ? , . i
ARREST WARRANT AFFIDAVIT INSTRUCTIONS STATE OF CONN6CTIGUT
CONTINUATION PAGE The jurat is to be completed for each page of the affidavit. SUPERIOR COURT
JD-CR-64a Rev. 10-04 The prosecutorial official and judge/judge trial referee are to date
C".G:S". § 54"-2a and sign or initial each page to ind~cate that they have re\tievved it.;
Pro Bk. Sec. 35-1, 36-2, 36-3

NAME AND RESIDENCE (Town) OF ACCUSED


Eddie PEREZ 59 Bloomfield Avenue, Hartford, CT COURT TO Hartford
BE HELD AT (Town) 14NO.
IG. A.

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

comer cat 80 grit sand paper 5 pack


Klean stripper mineral spirits quart
2 inch 30 amp 2 pole electrical breaker
Metal one hole cable strap electrical
5 pack 3/4" clamp connector electrical

THAT a Home Depot receipt, dated June 08, 2005, for $5.98, was found to be for the following:
1 1/4"x 8 ft comer bead for drywall
3 pack 9"x 11" 220 grit sand paper

THAT a Home Depot receipt, dated June 09, 2005, for $18.26, was found to be for the following:
2 pack sanding/drywall/fiberglass respirator
3" economy paint brush
Orange handle metal roller for painting
9" x W' roller semi-rough for painting
9" disposable paint tray

THAT on June 13,2005, the Steam Control Unit was shipped from Plimpton & Hills - (chrome to be exchanged late
for brass) $350.40.

THAT a Home Depot receipt, dated June 13,2005, for $99.86, was found to be for the following:
ITEM NOT ON FILE
2- disposable roller paint tray
Orange wire 5 inch paint roller frame
2- 2 W' Angle cut paint brush
3 Pack 3/8" Pylam Roller covers for paint

THAT a Home Depot receipt, dated Jlme 13, 2005, for $22.08, was found to for the following:
1"x3 "x8 ft #2 pine lumber
Primed base cap molding 12 ft.
Pine Base molding 12 ft.

THAT on June 15,2005, tile setting material was picked up at Daltile for a cost of$78.67.

THAT on June 15,2005, a fax request was sent to Intemational Granite and Marble for 140 square feet of EmperadoJ
Polished tile that was used on the bathroom floor and around the Jacuzzi. The cost of the tile was $1085.00 and was COD

(This is page 12 of a 25 Page Affidavit.)


DATE AND DATE SIGNED (Affiant)

SIGNATURE /-/.'5 -6'7


. Inspector Michael Sulliva.ni'U.$/..-
SIGNED
.'

(Jupge'/ ClerK,]Comm.
,
Sup. Ct,., Notary,8
JURAT
./ i 1"/
.~., ~
,SUBSCRIBED /• .•.SW.o."RN
AN? " !>.,.~ !
\"'.J
J' ' .... TqB.EFORE
,. ME ON (Date) .j '''<>/ """j:'~'{\ ;"",,'f""l-~. ""~ .

REVIEWEf1 (I?(~secuto~jal/)ffiSjal)
REVIEW§.Q_;-4l~~~3dge Trail Referee
' __._':(".'> ',_. r . C.·ilt
ARREST WARRANT AFFIDAVIT INSTRUCTIONS STATE OF CONN6GTICHT
CONTINUATION PAGE The jurat is to be completed for each page of the affidavit. SUPERIOR COURT
JD-CR-64a Rev. 10-04 The prosecutorial official and judge/judge trial referee are to date
C.G:S". §" 54.:.2a and sign or initial each page to indicate that they have r8vie\.A'!ed it.;
Pro Bk. Sec. 35-1, 36-2, 36-3

NAME AND RESIDENCE (Town) OF ACCUSED


Eddie PEREZ 59 Bloomfield Avenue, Hartford, CT COURT TO Hartford
BE HELD AT (Town) I G. A14NO.

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

corner cat 80 grit sand paper 5 pack


Klean stripper mineral spirits quart
2 inch 30 amp 2 pole electrical breaker
Metal one hole cable strap electrical
5 pack 3/4" clamp connector electrical

THAT a Home Depot receipt, dated June 08, 2005, for $5.98, was found to be for the following:
1 1/4"x 8 ft corner bead for drywall
3 pack 9"xll" 220 grit sand paper

THAT a Home Depot receipt, dated June 09, 2005, for $18.26, was found to be for the following:
2 pack sanding/drywall/fiberglass respirator
3" economy paint brush
Orange handle metal roller for painting
9" x W' roller semi-rough for painting
9" disposable paint tray

THAT on June 13,2005, the Steam Control Unit was shipped from Plimpton & Hills - (chrome to be exchanged late
for brass) $350AO.

THAT a Home Depot receipt, dated June 13,2005, for $99.86, was found to be for the following:
ITEM NOT ON FILE
2- disposable roller paint tray
Orange wire 5 inch paint roller frame
2- 2 WI Angle cut paint brush
3 Pack 3/8" Pylam Roller covers for paint

THAT a Home Depot receipt, dated Jtl11e13,2005, for $22.08, was found to for the following:
1"x3 "x8 ft #2 pine lumber
Primed base cap molding 12 ft
Pine Base molding 12 ft

THAT on June 15,2005, tile setting material was picked up at Daltile for a cost of$78.67.

THAT on June 15,2005, a fax request was sent to International Granite and Marble for 140 square feet of Em per ad OJ
Polished tile that ,vas used on the bathroom floor and around the Jacuzzi. The cost of the tile was $1085.00 and was COD

(This is page 12 of a 25 Page Affidavit.)


DATE AND IDATE SIGNED (Affiant)
SIGNATURE
/-/'"5 -07'. Inspector Michael Sulliva.ntH..$./~
" ,
q, Notary
." "
SUBSCRIBED

~ I ~,~~~I
ANQ SWORN TQ BEFORE ME ON (Date)
}·,3 ~.'{,
SIGNED (Jupg4/ ClerK,)Comm.
, ,.j"~/~~:~;:'/
Sup.
·.~.~.e'..I'~~~,..t~\ ?:s:~",;·,·;o·:;·/(r
;;.•.
P-

_",~~.;

REVIEWED
, : ...(l?r<;lsecutorial
~: --" ':}- ,Officjal)
,
"' ,.,'.'~<
_,_j_ :""~" C,"",.· REVIEW~.Jf~~~~dge Trail Referee
ARREST ,WARRANT AFFIDAVIT INSTRUCTIONS STATE OF CONNECTICUT
CONTINUATION PAGE The jurat is to be completed for each page of the affidavit. SUPERIOR COURT
JD-CR-64a Rev. 10-04 The prosecutorial official and judge/judge trial referee are to date
C.G.S. § 54-2a and sign or initial each page to indicate that they have reviewed it.;
Pr. Bk. Sec. 35-1, 36-2, 36-3

NAME AND RESIDENCE (Town) OF ACCUSED COURT TO BE HELD AT (Town) G. A. NO.


Eddie PEREZ 59 Bloomfield Avenue, Hartford, CT Hartford 14

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

THAT on June 16, 2005, Jeffrey Delgado and his helper tiled the bathroom floor and around the Jacuzzi. MI
Delgado's invoice was for 7 hours of labor.

THAT Jeffrey Delgado's invoice indicates that on June 17,2005 he grouted the tile for 8 hours.

THAT a Home Depot receipt, dated June 20,2005, for $93.47, was found to be for the following:
~ 4- 1"x 8"x 8" Select Pine lumber
Red rosin paper for flooring
Plastic Home Depot Bucket
3 gallon paint mixer
Alex plus clear caulking
White sealant caulking

THAT a Home Depot receipt, dated June 21, 2005, for $22.24 was for the following:
Premium Plus Flat Enamel Accent Gallon Paint.

THAT a Home Depot receipt, dated June 21,2005, for $98.26, was for the following:
Pine base cap molding 4 ft.
Fiberboard base molding 26 ft.
2- 12"x 6" ceiling register cap vent
6 pack 6 inch recessed lighting white
gray sealant caulking
2 pack yellow fuel cells for pneumatic nail gun

THAT on June 22,2005, minor installed by Metcalfe Glass $408.02.

THAT a Home Depot receipt, dated June 22, 2005, for $54.19, was for the following:
Turf builder Kentucky blue grass seed
4- 60 watt halogen flood light
4"x 3/8" smooth trim roller
2- 40 watt Durmax bent tip decorative light bulb
ITEM NOT ON FILE
Decorative Toggle light switch ivory
2- 1 gang dimmer switch cover plate almond
1 gang dimmer switch cover plate ivory
Duplex plate Ivory for dimmer switch

(This is page 13 of a 25 Page Affidavit.)


DATE AND I DATE SIGNED (Affiant)
SIGNATURE
Inspector Michael Sulliv~-:./,
JURAT SIGNED (Ju~€i/ Clyrk, Comm. Sup 8t.,~.t~ry,
./- ._..i>.~::.1> L.V~:;:r;.>1';'··i 4.~:"/:'>~'~:""'-~""-'-"''''
~:." Ii>

REVIS\NW (Judge / Judge Trail Referee


/' Ji...-r" -",---
....
_~{t/
ARREST WARRANT AFFIDAVIT INSTRUCTIONS STATE OF CONNEGTIC.lJJ
CONTINUATION PAGE The jurat is to be completed for each page of the affidavit.
The prosecutorial official and judge/judge trial referee are to date
,.. COURT
SUPERIOR
JD-CR-64a Rev. 10-04
CGS § 54-2a _ .?ng sign or initial each page to indicate that they have reviewed it.;
Pro Bk. Sec. 35-1, 36c2; 36-3

NAME AND RESIDENCE (Town) OF ACCUSED


Eddie PEREZ 59 Bloomfield Avenue, Hartford, CT COURT TO Hartford
BE HELD AT (Town) 14NO.
IG. A.

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

4 inch roller frame for paint

THAT on June 29,2005, a Home Depot receipt for $64.08 was for the following:
2- Premium plus flat enamel pastel gallon paint
ITEM NOT ON FILE
ITEM NOT ON FILE
~ 1 gang brown light switch plate cover
Stainless steel entry lock
3 pack 3/8" pylam paint roller cover

THAT on July 02,2005, a Home Depot receipt for $187.58 was for the following:
Fat Max Tape measure
8000 BTU Air Conditioner

THAT on July 07,2005, the custom shower door was ordered by Joe Nascimento - a deposit of $887.32 by check wa
made.

THAT on July 25,2005, the Steam Control Unit for shower shipped from Plimpton & Hills - this was the brass uni
exchanged for chrome unit - $350.40.

THAT on August 05,2005, shower door installed - balance paid $887.31.

THAT a Home Depot receipt, dated August 8, 2005, for $36.04, was found to be for the following:
base cap molding 6.67 feet
base fiberboard molding 1.17 feet
2"x 4"-8 ft pine stud
Kitchen and bath clear silicone caulking
ITEM NOT OF FILE
1/4" 4 pack toggle bolt for drywall
2 W' coarse drywall screws 1 lb box

THAT on August 29, 2005, an invoice indicates the purchase of an additional 10 square feet of Emper ad or Polished tile
from IGM for the cost of$80.50. John Haberlin, from Intemational Granite and Marble Corp. produced a check indicatinf
that USA Contractors paid this bill. Jeffrey Delgado had testified that he had run out oftile when he was doing the flom
and Jacuzzi area. He said that he wasn't interested in returning to finish the job. Photographs were taken of the interim
of the Perez residence by investigators. Upon looking at the photographs, Mr. Delgado said that someone else had

(This is page 14 of a 25 Page Affidavit.)


DATE AND I DATE SIGNED (Affiant)
SIGNATURE /-/3-0 Inspector Michael Sulliva!:!T0 :./,~
SUBSCRIBED AND SWORN TO,BEFORE ME ON (Date) SIGNED (Jud.ge/ Clerk, Comm. Sup. Ct., NO~ry Pu
JURAT " 1...

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ARREST-WARRANT AFFIDAVIT INSTRUCTIONS STATE OF CONNECTICUT
CONTINUAT~ON PAGE The jurat is to be completed for each page of the affidavit. SUPERIOR COURT
JD-CR-64a Rev. 10-04 The prosecutorial official and judge/judge trial referee are to date
C.G~·S. § 54-2a and sign or initial each page to indicate that they have reVie\A!ed it.;
Pro Bk. Sec. 35-1, 36-2, 36-3

NAME AND RESIDENCE (Town) OF ACCUSED


Eddie PEREZ 59 Bloomfield Avenue, Hartford, CT COURT TO Hartford
BE HELD AT (Town) 14NO.
IG. A.

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

obviously finished the tile work.

THAT testimony and exhibits presented to the Grand Jury indicate that USA Contractors paid for all materials used a
the Perez residence at the time of purchase or shOlily thereafter. Some of those costs were then passed on to Eddie Pere
in the form of a "bill" from USA Contractors in February 2007. Evidence presented to the Grand Jury indicates that th
renovations at the Perez residence were substantially completed in the summer of2005.

THAT on 03/25/2008 Erica Perreault testified before the Grand Jury. Perreault worked for Carlos Costa from Februar:
2004 to June 2006. Perreault testified that she worked with customers interested in counter tops. Perreault provided quote:
to customers, ordered counter tops, etc ... Perreault stated she recalled Eddie and Maria Perez came to Carlos Costa':
showroom at 110 AirpOli Road, Hartford to look at counter tops.

THAT Perreault was shown the EleMar Granite and Marble order fonn for an Emperador Dark counter top. Perreaul
acknowledged she ordered the stone but did not recall the customer. Perreault was also shown a photograph of the Perei
bathroom renovations. Perreault indicated the counter top depicted in the photograph was Emperador Dark. Perreaul
stated the Emperador Dark counter top would typically have been sold by Costa for $50-$55 a square foot. Perreault alsc
testified that Costa charged $150 or $250 (depending on the time frame) to cut sink holes in the counter top. Perreault statec
the backsp1ash on the counter top was typically $20.00 a linear foot.

THAT Perreault was shown a photograph of the counter top in the kitchen of the Perez residence. She identified the
counter top as Juparana Bordeaux. Perreault stated that Costa typically charged $70-$75 a square foot for Juparan3
Bordeaux plus the sink cut outs.

THAT Perreault was shown several sample quotes/bills obtained from the USA Contractors computer in the possession
of the Office of the Chief State's Attorney. Perreault identified the quote fonn as a standard quote fonn that identified
various pricing used by Costa. Referring to the quote form, Perreault identified a four inch back splash as $20.00 a linear
foot, under mount sink cut out as $250.00, above mount sink cut out as $150.00. The quote form indicated that 90% was
due before the order and work was done. Perreault explained that 90% was typically charged up front as once the stone
counter tops were cut they typically could not be used by anyone else as every customers measurements are different.
Perreault stated that the balance of 10% would be paid upon completion of the work plus tax on the entire amount.

THAT Perreault was shown the USA Contractors invoice for the renovation work done at the Perez residence. Perreault
noted that a charge for the bathroom counter top, counter top back splashes), and tax charges are not noted on the invoice.

THAT the Depaliment of Consumer Protection conducted an investigation into the renovations done at 59 Bloomfield
Avenue. It was detel111ined that the work was done without permits or inspections. In addition, the electrical work was

This is page 15 of a 25 Page Affidavit.)


DATE AND IDATE SIGNED (Affiant)
SIGNATURE
/ -/3 Inspector Michael Sulliva!J.,4:."
SUBSCRIBED AND SWORN TO 1i\.~FORE ME ON (Date)
SIGNEQ (~.l,Ijge/ Cle;~, ~?mm. Sup. G.t" N~ry P
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ARREST WARRANT AFFIDAVIT INSTRUCTIONS STATE OF CONNECTICUT
CONTINUATION PAGE The jurat is to be completed for each page of the affidavit. $UPE~IOR CQURT
JD-CR-64a Rev. 10-04 The prosecutorial official and judge/judge trial referee are to date
C.G,S. § 54-2a and sign or initial each page to indicate that they have reviewed it.;
Pro Bk. Sec. 35-1, 36-2, 36-3

NAME AND RESIDENCE (Town) OF ACCUSED


Eddie PEREZ 59 Bloomfield Avenue, Hartford, CT COURT TO Hartford
BE HELD AT (Town) 14NO.
/G. A.

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

done by an unlicensed worker. Ramiro Morales was fined for doing the electrical work. Donald Sullivan and SOl
Plumbing was also found to be in violation and fined for doing plumbing work without a pennit. It was also determine
that USA Contractors was not registered. as a home improvement contractor. The Department of Consumer Protectic
levied fines as a result of the violations.

THAT on 08/23/2007, Mayor Perez applied for building pennits for the renovation work that was done in 2005. Ci1
~ of Hartford Director of Licensing and Inspection, Dinesh Patel, testified before the grand jury that the building pelmi
should have been obtained prior to the contractors commencing work at the Perez residence.

THAT testimony and exhibits presented to the Grand Jury indicate that Carlos Costa is the owner/operator ofthe Carioc
Club, located on Newfield Avenue, Hartford.

THAT City ofHaliford records indicate that Carlos Costa did obtain numerous building pemlits over the years for wor
done to his Carioca Club. However, no building permits were obtained for work at Mayor Perez's residence unt
investigators uncovered the renovation work.

THAT the investigation found numerous instances where Mayor Perez apparently intervened in matters to benefit Carlo
Costa or Carlos Costa obtained assistance from Mayor Perez to benefit himself (Costa).

THAT the Carioca Club is located at 145 Newfield Street in Hartford. The club is owned and operated by Carlos Coste
An email from John Palmieri, Director of Development Services, to Roger O'Brien, Director of Planning, dated 11/26/200,
said, "Mayor called Mr. Carlos Costa (#398-0480) wants to add 25x60 addition to club on Newfield (off Flatbush behinl
Walmart) and wants to know whether he "vvillconfront zoning issues. Please call Mr. Costa to arrange a consultation a.
courtesy to the Mayor. A portion of his property apparently resides in W Hartford. Examine issues and stop in to see m,
before Mr. Costa is contacted. Thanks." Palmieri acknowledged that Mayor Perez called him with the forgoing request
A series of emails aloeexchanged by Palmieri's subordinates as they work on the favor to Mayor Perez. Palmieri the!
reports back to Kelvin Roldan, via email, when his (Palmieri's) subordinates have completed their work. Roldan fOlwarde<
the string of emails explaining what work was done to "Willie Nunez. "

THAT one of Palmieri's subordinates who worked on the Carioca Club favor for Mayor Perez was Marina Rodriguez
Chief Staff Planner. Rodriguez testified before the Grand Jury that she did receive Palmieri's email asking that assistanc(
be given to Carlos Costa per Mayor Perez. Rodriguez testified that since the contents of the emails were a request fron
Mayor Perez it indicated to ber that sbe needed "to do this sooner rather than later. "

THAT Mark Wiles, former City of Hartford employee charged with administering erriail accourits', testified before the
Grand Jury. Wiles testified that he created the "Willie Nunez" email account on 02/24/2004. Wiles testified that the

(This is page 16 of a 25 Page Affidavit.)


DATE AND I DATE SIGNED (Affiant)
SIGNATURE
/-/3 -0 Inspector Michael Sulliva~·u
JURAT SUBSCRIBED ~ND S~ORN Tp BEFORE ME ON (Date) SIGNED (Ju~ Cler}',~omm. s~~;/Ct:. N
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ARREST 'WARRANT AFFIDAVIT INSTRUCTIONS STATE OF CONNECTICUT
CONTINUAnON PAGE The jurat is to be completed for each page of the affidavit. SUPERIOR COURT
JD-CR-64a Rev. 10-04 The prosecutorial official and judge/judge trial referee are to date
C.G.S. § 54-23 and sign or initial each page to indicate that they have reviewed it.;
Pro Bk. Sec. 35-1,36-2,36-3

NAME AND RESIDENCE (Town) OF ACCUSED


Eddie PEREZ 59 Bloomfield Avenue, Hartford, CT COURT TO Hartford
BE HELD AT (Town) 14NO.
/G. A.

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

"Willie Nunez" account belongs to Mayor Perez. Wiles testified that he used the fictitious name "Willie Nunez" to set u
the account at the request of Susan McMullan, a staff member of May or Perez's. Wiles testified that to his knowledge thj
was the only fictjtious account set up on the City of Hartford's emajl system. McMullan told Wiles that the purpose ofth
account was for intemal use as Mayor Perez's regular email account received a lot of emails.

THAT Kelvin Roldan, Special Assistant to the Mayor, acknowledged that the "Willie Nunez" email account belongel
, to Mayor Perez. Roldan was asked why he would forward something to the "Willie Nunez" account versus Mayor Perez'
regular email account. Roldan testified that he would send the item to the "Willie Nunez" account "if it's something tha
is in front of me at the time, bearing some kind of importance that 1 think the Mayor should know, on a more quicke
fashion. "

THAT testimony before the Grand Jury was that in 2003 the City of Hartford bid the Park: Street Improvement Project
The job was to rehabilitate the infrastructure along Park Street in Hartford. The initial contract was in excess of$5 million
USA Contractors was the low bidder and was awarded the contract. Testimony indicated that during the Park Stree
Improvement Project, conflicts arose between City inspectors and USA Contractors. The complaints by the inspector;
centered mainly on their claims that the proj ect was rumling late, the workmanship was inferior and that Carlos Costa I US)
Contractors was trying to bill the City of H31iford for in excess of a million dollars wOlih of "Ch311georders," which th(
City's Public Works officials felt that they were not entitled to under the contract. Urban Engineers, a private engineerin~
finn, was contracted by the City of Hartford to basically mediate between USA Contractors and the City of Hartford ane
determine if USA Contractors claims had any merit.

THAT Mayor Perez had several meetings with Carlos Costa, Public Works officials, and others in an effort to mediate
these differences. On May 6,2007, Jolm H. McGrane, Assistant Director of Public Works and City Engineer for the Cit)
of Hartford, sent a certified letter to the bonding company that had insured USA Contractors on the Park Street proj ect
advising them that the City was seeking options against the bond for USA Contractors' failure to complete the project ir
a timely manner. After leaming ofthe bonding company letter, Mayor Eddie Perez called a meeting in his office where he
discussed the bonding company letter and voiced his displeasure. Testimony revealed that Perez then ordered his DirectOI
of Capitol Projects, Charles J. Crocini to pull back the calling of the bond. Crocini advised that he would take care of it.
Crocini followed up with a letter dated May 16, 2006, advising the bonding company that the intent of the first letter from
John H. McGrane was "to serve as notice, only to the bonding company, and there is no wish at this time, to execute an}
action against the contractor, USA Contractors, Inc." The letter was in effect withdrawing the City's claim against the
bond.

THAT one ofthe problems described in testimony was the fact that Carlos Costa would communicate with the Mayor's
Office, Urban Engineers, and various. Public Works employees altemately. This was problematic in that the
communications were not centralized nor coordinated.

(This is page 17 of a 25 Page Affidavit.)


DATE AND I DATE SIGNED (Affiant)
SIGNATURE
/-/3'-0'7 Inspector Michael Sulliva'lZ/. ~.
.

SUBSCRIBED AND SWORN TO ~EFORE ME ON (Date) SIGNED (JudgeWfer~.,;Comm. Sup. Ct., Noiary Pu
JURAT
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ARREST WARRANT AFFIDAVIT INSTRUCTIONS STATE OF CONN6CTIClH
CONTINUATION PAGE The jurat is to be completed for each page of the affidavit. SUPERJORCo.URT
JD-CR-64a Rev. 10-04 The prosecutorial official and judge/judge trial referee are to date
C.G.S. § 54-2a and sign or initial each page to indicate that they have revie\ved it;
Pre Bk. Sec. 35-1, 36-2, 36-3

NAME AND RESIDENCE (Town) OF ACCUSED COURT TO BE HELD AT (Town) G. A. NO.


Eddie PEREZ 59 Bloomfield Avenue, Hartford, CT Hartford 14

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

THAT on 05/17/2006 Urban Engineers issued a written "Park Street Communication Protocol" to Carlos Costa. Tt
protocol defined lines of communication to be used for the Park Street proj ect in an attempt to coordinate activities. Cos1
was to communicate with Urban Engineers so that construction activities would be coordinated and centralized.

THAT upon receiving the communication protocol, Carlos Costa wrote back to Urban Engineers, "In communicatio
with Mr. Charles Crocini last Friday May 12, 2006 we, I was directed toforward all future communications to himself an
, his office. I
verified this again today about 10 minutes ago. USA Contractors will forward out communications to U
Charles Crocini's offices. "

THAT examination of Mayor Perez's appointment calender indicated that on 09/23/2006 he was scheduled to preser
a Proclamation and Key to the City in an event at the Carioca Club. Carlos Costa is listed as the contact person along wit
his (Costa's) telephone number. Testimony from Barbara Crockett, Mayor Perez's Executive Assistant, was that Carlo
Costa called requesting that Mayor Perez present a Proclamation and Key to the City to a guest (Tito Nieves) at the Carioc
Club. Crockett indicated that presentation of a Key to the City is a relatively rare event. She guessed that Mayor Perez ha
made such a presentation less than twenty times in the last four years. Crockett provided a Key to the City log that indicate
only 11 were presented in the period 2006-January 2008.

THAT Celestino Jimenez testified before the Grand Jury. Jimenez was the City of Hm1ford employee that oversaw th
Park Street contract for minority pmiicipation compliance. Jimenez stated he did patronize the Carioca Club several time~
Jimenez stated he attended a Tito Nieves concert at the Carioca Club. Jimenez stated that Mayor Perez and his wife wer,
present along with Carlos Costa. Jimenez stated that Mayor Perez gave a proclamation to Nieves that day. Jimenez state(
there was a "V.I.P" section for invited guests. Mayor Perez, his wife, and Costa were in that section. Jimenez was no
permitted in.

THAT testimony revealed that Carlos Costa and Mayor Perez have more than a normal business relationship. Testimon~
indicate that Mayor Perez has intervened on Carlos Costa's behalf in his dealings with the City of Hartford. One sud
example ofthe Mayor's intervention for Carlos Costa was found in the intemal emails that were obtained from the City 0
Hartford. The emails indicate that on at least four occasions Mayor Perez ordered manual checks to be cut for the wod
perfonned by USA Contractors, Kathleen Palm-Devine, Hartford's City Treasurer testified that the issuance of manu a
checks is a mechanism used to address emergency or short notice situations. The four instances found are described a~
follows:

1) Mayor Perez's appointment calender shows that he had a .'private meeting" with Carlos Costa on 03/30/2006
Mayor Perez's telephone records show that he called Carlos Costa on 03/29/2006. Carlos Costa signed a City 01
-Hartford App1icati6ii and Certificate forPaY1n~mt oii 04-/06/2006.- The requ'est was for a $'187,046.81 payment fOJ
work that USA Contractors performed for the Hartford Parking Authority. A City of Hartford representative signee

(This is page 18 of a 25 Page Affidavit.)


DATE AND IDATE SIGNED (Affiant)
SIGNATURE
Inspector Michael Sullivaq~
SUBSCRIBED AND.SWOI)N TO BEFORE ME ON (Date) SIGNED (J\)qge/ 9i¢rk, Comm. §.uP, Ct., No
JURAT
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.. _.f:" /" /,- (--~"Yli ~J'-'" '.
-ARRESTWARRANT AFFIDAVIT INSTRUCTIONS STATE OF CONNECTICUT
CONTINUATION PAGE The jurat is to be completed for each page of the affidavit. SUPERIOR COURT
JD-CR~64a Rev '10-04 The prosecutorial official and judge/judge trial referee are to date
G.GS. § 54.-2a and sign or initial each page to indicate that they have reviewed it.;
Pro Bk. Sec. 35-1, 36-2, 36-3

NAME AND RESIDENCE (Town) OF ACCUSED


Eddie PEREZ 59 Bloomfield Avenue, Hartford, CT COURT TO Hartford
BE HELD AT (Town) IG. A.14NO.

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

the document approving payment on 04/14/2006. Telephone records indicate several calls between Costa and Pere
on 04/24/2006 and 05/11/2006.

On 05/16/2006 Finance Director Thomas Morrison wrote to City Treasurer Kathleen Palm-Devine asking her fo
the $187,046.81 check. Monison indicates that the payment is an emergency and that the request is coming fror
the Mayor's Office. Palm-Devine objects and writes back inquiring why contractors are being paid manuall
causing the city to lose "float." The tel111"float" refers to the interest that is gained while payments go throug]
the nonnal course of business. The $187,046.81 check is issued the same day, 05/16/2006.

2) Examination of Mayor Perez's telephone bills shows that he called Costa on 06/07/2006. Costa signed anothe
request for payment on 06/09/2006 in the amount of $211,539.25. The payment was for work USA Contractor
perfonned on Park Street. The City of Hartford signed and approved payment the same day. Examination 0
telephone records indicates several telephone calls between Mayor Perez and Costa on 06/09/2006,06/12/2006, anc
06/14/2006.

On 06/14/2006 Deputy Finance Director Christian Johnson sent an email to Kathleen Palm-Devine entitled
"Mayor's Office Emergency Check Request. " Johnson asks Palm- Devine to process the payment on an "emergencJ
basis" as "the lvlayor 's Office wants this one." The check is issued the same day. Thomas Morrison writes tc
Palm-Devine and thanks her for h.er help.

3) Examination of telephones records indicates numerous calls between Costa and Mayor Perez in February 200~
and March 2007. On 03/13/2007 Costa signed an Application and Certificate for Payment in the amount OJ
$481,919.37 for work performed for the Hmiford Parking Authority. A City of Hartford representative signed ane
approved the payment on 03/17/2007.

On 03/30/2007 Christian Johnson writes an email to Palm-Devine saying, ''The Mayor wants to have a manual
[emergency} check run for USA Contractors" for $481,919.37. The check is issued the same day. Thoma5
Monison writes and thanks Palm-Devine.

4) Examination of telephones records indicates numerous calls between Costa and Mayor Perez in February 2007
. and March 2007. On 03/20/2007 Costa signed an Application and Certificate for Payment in the amount of
$189,751.82 for work perfonned for the Hmiford Parking Authority. A City of Hmiford representative signed and
approved the payment on 03/21/2007.

On 03/30/2007 Christian Johnson writes ai1email (same email as number 3) to PalIn-Devine saying, "The Mayor
wants to have a manual [emergenc}] check run for USA Contractors" for $189,919.37. The check is issued the

(This is page 19 of a 25 Page Affidavit.)


DATE AND IDATE SIGNED (Affiant)
SIGNATURE
/~/-.S -09
. Inspector Michael Sulliva.!l2.Z
JURAT SUBSCRIBED AND SVYORN T9 BEFORE ME ON (Date) SIGNED (JUd.wr/C1w~, Comm. S~J)i ~t.,
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-...-• .- •.-.- .••-':;OO'OkiO"-.........-.-.-r"l-,""'-.-'"l'""\rv I~Rr r-' U r\ V, , INSTRUCTIONS STATE OF CONNECTIC~T
CONTINUATION PAGE The jurat is to be completed for each page of the affidavit. SUPERIOR COURT
r
JD-CR-64a Rev. 10-04 The prosecutorial official and judge/judge trial referee are to date
C.G.S. § 54-2a and sign or initial each page to indicate that they have reviewed it.;
Pr. Bk. Sec. 35-1, 36-2, 36-3

NAME AND RESIDENCE (Town) OF ACCUSED


Eddie PEREZ 59 Bloomfield Avenue, Hartford, CT COURT TO Hartford
BE HELD AT (Town) 14NO.
IG. A.

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

same day. Thomas Monison writes and thanks Palm-Devine.

THAT examination of City of Hartford emails found a 05111/2006 email from Thomas MOlTison which reads in par
"1 have signed a voucher to transfer $249,000 from a bond of $6,000,000 for street construction to the private duty pa.
accounts for public works PJ work." The email goes on to read, "I will also make sure we get out $125,000 fi'om US.I
Contracting, who currently has 2-3 jobs with the City. .. I did tell everyone that we would get this money back through th
Civic Center money. "

THAT an email, apparently in response to Monison's 05111/2006 email, was sent by Corporation Counsel Jolm Rosl
to MOlTison and copied to Mayor Perez. The subject reads, "USA PRIVILEGED AND CONFIDENTIAL. " The emails goe,
on to read, "Tom, I believe that USA owes the City a bunch of money re private duty police; and their pelformance to dati
on the Park Street project leaves a lot to' be desired. I will speak to DPW to get the latest and then talk to the Mayor
JohnRose. " MOlTison responds in an email, "1understand. He asked lne to get them paid. We are left to try and get fimd.
from them through the project. 1 will discuss with you. TJM"

THAT Christian Johnson testified before the Grand Jury on 02/26/2008. Johnson is the Deputy Finance Director fo:
the City of Hartford. Johnson stated that the City of Hartford should be paying invoices within 30 days. However, Johnsor
stated invoices are typically paid in about 50 days. Johnson was questioned about the term "float" as used in the previous 1)
described email from Palm-Devine. Jolmson stated that "float" refers to the interest earned by the City on money for th~
period when the check is issued until it is cashed. Jolmson stated that the interest on money is lost when the City runs ar
"emergency" or "manual" check. Johnson stated these interest eamings are important to the City in the long run. Jolmsor
stated that 90% of the time an "emergency" or "manual" check is sought it is because the vendor is late in getting paid.

THAT Clu'istian Johnson was asked questions relative to the four "emergency" or "manual" checks described previously.
Johnson was asked if the fact that the request for payment comes from the Mayor gives the request a sense of priority.
Jolmson indicated that it does. Johnson further stated that it was "unusual" for the Mayor to get involved in requesting that
"emergency" or "manual" checks be issued.

THAT on 02/26/2008 Kathleen Palm-Devine testified before the Grand Jury. Palm-Devine is the elected City Treasurer
[n the City of Hartford. Palm-Devine is responsible for, among other things, the issuance of checks to vendors doing work
for the City of Hartford. Palm-Devine stated that it is the goal ofthe City to issue checks about 30 days after a request from
3. vendor to do so. Palm-Devine stated that there are occasions in which "emergency" or "manual" checks are cut for
various reasons. Palm-Devine stated that when checks are issued in this mam1er under the 30 day threshold the City loses
noney by not being able to collect the interest on the money. Palm-Devine also stated that the process of issuing
'emergency" or·'-'manual :".checks is very-labor intensive and much InUTe' experrsIve than iithe check is issllediifthe 110tmal
~ourse of business.

This is page 20 of a 25 Page Affidavit.)


DATE AND I DATE SIGNED (Affiant)
SIGNATURE /-/3-0 Inspector Michael Sullivan...;l""u,
SUBSCRIBED AND SWORN. TO BEFORE ME ON (Date) SIGNED (Judg~ICler~, Comm. Syp.p., N~~ry Pub"
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AKKt:~ I ,WAKKAN r AFFIDAVIT INSTRUCTIONS STATE OF CONNECTICUT
CONTINUATION PAGE The jurat is to be completed for each page of the affidavit SUPERIOR COURT
JD-CR-'64a Rev.'10-04 The prosecutorial official and judge/judge trial referee are to date
·C.G.S. § 54-2a .. and sign or initial each page to indicate that they have reviewed it;
Pr. Bk. Sec. 35-1, 36-2, 36-3

NAME AND RESIDENCE (Town) OF ACCUSED


Eddie PEREZ 59 Bloomfield Avenue, Hartford, CT COURT TOHartford 14NO.
BE HELD AT (Town) IG. A.

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

THAT Palm-Devine stated that in addition to the previously described "emergency" or "manual" checks issued to US)
Contractors there have been 3 or 4 other requests made by Thomas MOlTison on behalf of USA Contractors. Palm-Devin
stated she refused these other requests.

THAT Palm-Devine was asked how often the Mayor or Mayor's Office intervenes to have "emergency" or "manual
checks issued. Palm-Devine stated that it was rare.

THAT David Carson is Chainnan of the Hmiford Parking Authority. Carson stated that emergency work was being doni
on the Church Street Parking Garage in Hartford by USA Contractors. The emergency work was nearing completion ant
the City of Hartford \vas preparing to competitively bid the remainder of the work. This would have been in 2005/2006
Carson stated that Mayor Perez did approach him and ask if the new contract was going to be a minority set aside contract
Carson told Mayor Perez it would not be. Carson felt it was in the City of Hartford's best interest to have a wide spectrun
of contractors bid on the new contract and acknowledged that giving the contract minority set aside status would havt
limited the pool of potential bidders.

THAT USA Contractors is a certified Minority/Women Business Enterprise in the City ofHmiford and would be eligible
to bid on any contract requiring such. James Kopencey, Executive Director ofthe Hartford Parking Authority, testified tha
USA Contractors would be the only qualified bidder on a parking garage contract if the contract were to be a minority se
aside contract

THA T Elza Ribeiro testified before the Grand Jury. Ribeiro is the Secretary for USA Contractors. Ribeiro was askec
if she ever contributed to Mayor Perez's reelection fund. Ribeiro stated she contributed $250.00 in 2007 in the form of a
personal check from Sovereign Bmue Ribeiro stated she was not reimbursed by anyone for the contribution. Ribeiro stated
she gave the check to Carlos Costa.

THAT investigators obtained a Campaign Finance Disclosure Statement from the Connecticut State Elections
Enforcement Commission. The documents indicate that Ribeiro donated $500.00 to the campaign. Ribeiro stated she did
not fill out the paperwork and stated she did not give $500.00. Ribeiro's weekly net pay check is $581.43.

THAT the City of Hmiford's Code of Ethics was made an exhibit before the Grand Jury. The Code of Ethics reads in
peliinent part, "No individual who is an officer, official [Jvfayor Perez}, employee, or member of any board, commission
or agency, whether paid or unpaid, shall engage in any business or transaction or have a financial, or personal, interest,
direst or indirect, which is incompatible with the proper discharge of the individual's official duties in the public interest
'Jr would tend to impair the Individual's independence of judgement and action in the pelformance of the Individual's
'JfJicial duties .. Nor shall the Individual engage in any financialdealings with an)lpersons- whoaetlvities are.regulated 01'
)upervised by the Individual's department, board, commission or agency or accept a gift from such persons. "

This is page 21 of a 25 Page Affidavit.)


DATE AND IDATE SIGNED (Affiant)
SIGNATURE -09
. Inspector Michael Sullivan '.
SUBSCRIBED AND SWORN TO BEFORE ME ON (Date) SIGNED (Ju~rq~rk, Comm. s,yp.Ct., No
JURAT . '1 . (.:.

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DATE
REyr ~wi~:'~~rfs,~tu~?:-,ii3~pffi ciaI) RE)lJE"'o/0 (Judge / Judge Trail Referee
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,","'''C-:l I VVMI"'U~1-\I'\I1 J-\rrIUA.VII INSTRUCTIONS STAI E OF CONNE.CTIC~T
CONTINUATION PAGE The jurat is to be completed for each page of the affidavit. SUPERIOR COURT
JD-CR-64a Rev. 10-04 The prosecutorial official and judge/judge trial referee are to date
C.G.S. § 54-2a and sign or initial each page to indicate that they have reviewed it.;
Pro Bk. Sec. 35-1, 36-2, 36-3

NAME AND RESIDENCE (Town) OF ACCUSED


Eddie PEREZ 59 Bloomfield Avenue, Hartford, CT COURT TO Hartford
BE HELD AT (Town) 14NO.
IG. A.

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

THAT Thomas Morrison testified before the Grand Jury on 04/01/2008. Morrison was given a non prosecution lett(
by the Office ofthe Chief State 's Attorney prior to his testimony. Morrison stated he was appointed as the Finance Directc
by Mayor Perez in April 2003. Morrison described himself as the chief financial officer for the City of Hartford.

THAT Morrison stated he was aware that Carlos Costa was the owner of USA Contractors and that USA ContractOl
was the contractor on the Park Street project. Morrison stated that Mayor Perez called him "out of the blue" in 200:
Mayor Perez indicated that Carlos Costa was a friend of his. Mayor Perez indicated that Costa was having a problem gettin
• paid on a particular invoice. Mayor Perez asked Morris0l1 to look into it and get back to him (Mayor Perez). Morrison di,
intervene and get a check issued to Costa. Morrison stated he was not aware at the time that Costa was doing renovatio
work at the Perez residence or he "would have ran in the other direction." Morris0l1 indicated Mayor Perez asked hin
on several occasions to intervene and issue a check to Carlos Costa. Morrison stated that he did as directed each time.

THAT Morrison described Mayor Perez intervening to get a contractor paid as infrequent. Morrison could not recal
Mayor Perez ever intervening on behalf of another contractor for payment.

THA Ton 04/15/2008 Christopher Brewer testified before the Grand Jury. Brewer stated he worked for USA Contractor
from October 2004 - December 2006. Brewer was hired by Costa to pursue USA Contractors claims against the City fo
compensation for work done that was in dispute between the City and USA Contractors. Brewer stated that Costa gave th(
claim package to Mayor Perez in addition to Public Works personnel.

THAT Brewer stated that one time during his employment with USA Contractors he was sent to a diner on Pratt Street
Hartford. Costa was having breakfast with Mayor Perez. Brewer had to bring Costa $20.00 because Costa did not hav(
any money to buy breakfast. Brewer stated that Costa later paid him back.

THAT Brewer stated that during his employment with USA Contractors he was not aware of any home improvemen1
work done by USA Contractors.

THAT on 06/19/2008 Carlos Costa testified before the Grand Jury. Costa testified that he was awarded the Park Streel
reconstruction contract by the City of Hartford around October 2003. Costa began actual work on the project on
04/15/2004. The value ofthat contract was approximately $5.3 million. Costa stated that from the proj ect' s inception there
were "a lot of problems." Costa described a host of construction related problems that continually mounted during the
:ourse of the project.

THAT Costa stated that he has known Mayor Perez since the mid 1990's. Costa met Mayor Perez in the performance
)f work he (Costa) was doing -in-the City of Hartford. Costa- stated that he-did-not have a relationship with- Mayor Perez
)ther than to greet him when they met. Costa stated that approximately 2004, after he started the Park Street work, his

22 of a 25
This is page Page Affidavit.)
DATE AND IDATE SIGNED (Affiant)
SIGNATURE /-/3-& ...
·· Inspector Michael Sulliv<:I
SUBSCRIBED AND SWORN TO BEFORE ME ON (Date) SIGNED (Jl,jcr~e/ Clo/k, Comm. S~, Ct.,
JURAT
...
/ ...,/;~"t~ C.··(:! ..-(.-/" v;:'-J···\.. .~...
--··-..t;'- {., '~

REVIEVVltb/(PJ6~e'cutorial Official) D~TE., ... ,


_ ...__. ;.::~~;_~)( (.4....;!.:~_u_ //- / ~.-c-:.~/'--::'~_>
....
, ARREST. WARRANT AFFIDAVIT INSTRUCTIONS STATE OF CONNECTICUT
CONTINUAT,ION PAGE The jurat is to be completed for each page of the affidavit. SUPERIOR COURT
JD-CR-64a Rev. 10-04 The prosecutorial official and judge/judge trial referee are to date
C.G.S. § 54-2a and sign or initial each page to indicate that they have reviewed it.;
Pro Bk. Sec. 35-1, 36-2. 36-3

NAME AND RESIDENCE (Town) OF ACCUSED


Eddie PEREZ 59 Bloomfield Avenue, Hartford, CT COURT TO Hartford
BE HELD AT (Town) 14NO.
IG. A.

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

relationship with Mayor Perez developed to a point where he (Costa) could pick up the telephone and speak directly wit
Mayor Perez about issues or concems that he was having. Costa stated that at the same time he was working on the Churc
Street Garage and MAT Garage for the City of Hartford under a multi-million dollar contract.

THA T Costa stated that USA Contractors was a minority business enterprise (MBE) certified by the City of Hartforc
Relative to the parking garage work Costa stated that he was one of the few MBE companies in the City of Hartfor
~ qualified to do that type of work. Costa was asked if Mayor Perez asked that the parking garage contract be designated
MBE contract would that benefit Costa. Costa stated, "Absolutely. "

THAT Costa stated that approximately the spring/summer of 2005 he was in his Hartford office. Mayor Perez and hi
(Mayor Perez) wife walked into the showroom. Mayor Perez wanted granite counter tops for his residence. Costa assiste,
Mayor Perez and the Perez' picked out a countertop. Costa stated that a price range was not discussed. Costa stated th3
he did not expect to be paid for the work. Costa explained that Mayor Perez was the Mayor of the City of Hartford wher
he (Costa) was doing millions of dollars of work. Costa described the situation as the "cost oime doing business with th-
City." Costa was asked what would happen ifhe had not done Mayor Perez's work for free. Costa stated he believed 11<

would have been "persona non grata" al?-dnot looked upon favorably by the powers that be in the City. Costa stated 11<

felt he would be "black balled" as a contractor in the City. Costa stated that by working at Mayor Perez's residence fo
free he expected to gain "access" to Mayor Perez. Costa described this access as being able to call or see Mayor Pere:
when he had a problem.

THAT Costa stated that after the Perez' selected the granite for the counter top Costa had his employees install th(
counter tops in the kitchen. While at the Perez residence Maria Perez (Mayor Perez's wife) spoke to Costa about th(
possibility of merging t\\lObathrooms on the second floor into one bathroom. Costa looked at the bathrooms alld informec
Maria that he could do the job. Costa stated that at Maria's urging he renovated the two second floor bathrooms into one
sanded and refinished the wood floors in the residence, and painted the walls on the interior ofthe house. Costa stated thl:
bathroom( s) renovation consisted of new flooring, new sheet rocked walls, installation of a steal11shower, installation oj
a Jacuzzi, installation of a double sink and cabinets. Costa described the renovation project as a "substantial undertaking. ,
All the costs incuned were paid for by Costa. Costa stated that Mayor Perez nor Maria ever spoke about the cost of the
work being perfonned. Costa stated he never gave the Perez' an estimate or proposal. Costa stated the renovation project
at the Perez residence was completed in 2005.

THAT Costa stated that somewhere towards the end of2006 Mayor Perez asked Costa for a bill relative to the renovation
work. Costa stated that Mayor Perez informed him (Costa) that rumors were circulating the community that Costa
perfonned free work for Mayor Perez. Mayor Perez named .TackSantos (.Toaquim Espirito-Santo) as one of the people
circulating this runior. Costa stated -that Mayor Perez felt the issue could spell trouble for him (Mayor Perez) ifsomeone
looked at it. Costa told Mayor Perez he (Costa) would put together a bill in the mid to high 20's ($20,000). Costa estimated

23
~This is page of a 25 Page Affidavit.)
DATE AND I DATE SIGNED (Affiant)
SIGNATURE -c) Inspector Michael Sulliva~
SUBSCRIBED AND ..SWORN TO;BEFORE ME ON (Date) SIGNED (JU9g~i C}e[k, Comm. Sup. Ct., N
./~;'>r../ .. ) .... ~~.' I ._,'~<.. ,v~':!/ <. ~~,... ~~~~t~.~
J~...~~- .(~

REVIEWED (Judge / Judge Trail Referee DATE; < /

:/_.•.• ~Y't '/ 1.--


;~ --- C3 [ ( 2-& /;~)~l
ARREST WARRANT AFFIDAVIT INSTRUCTIONS STATE OF CONNECTICUT
CONTINUATION PAGE The jurat is to be completed for each page of the affidavit. SUPERJOR COURT
JD-CR-64a Rev. 10-04 The prosecutorial official and judge/judge trial referee are to date
eG.s" § 54-2a and sign or initial each page to indicate that they have reviewed it.;
Pro Bk. Sec. 35-1, 36-2, 36-3

NAME AND RESIDENCE (Town) OF ACCUSED


Eddie PEREZ 59 Bloomfield Avenue, Hartford, CT COURT TO Hartford
BE HELD AT (Town) 14NO.
IG. A.

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

the actual cost of work done at the Perez residence as being approximately $40,000.00. Costa indicated he was just puttir
together a bill so Mayor Perez could justify whatever he (Mayor Perez) had to justify. Costa stated that Mayor Pen
indicated he did not have the money to pay the bill and had to secure a loan. Costa stated that Mayor Perez was shockc
that the bill would be so high. Costa eventually put together a bill that totaled $20,217. Costa identified as that bill. Cos
aclmowledged that the bill was not an accurate accounting of the work done at the Perez residence. The bill packat
contains a sketch of the Perez kitchen counter tops. Costa stated he made this sketch at the time he prepared the bi
~ (February 2007) to make the billing package appear more legitimate. Costa gave the bill to Mayor Perez in February 200'
Costa stated he received a check from Mayor Perez for $20,217 in July 2007.

THAT Costa stated that during the COUl'seof2005 and 2006 he called Mayor Perez directly and met with him personalJ
several times.

THA T Costa stated that at one point during the Park Street Project the City of Hartford sent a letter to his bondin
company in an attempt to terminate his construction bond with the City. Costa stated he asked Mayor Perez for his (Mayc
Perez) intervention. Costa stated this resulted in Charles Crocini writing a second letter to the bonding company indicatin
the City of Hartford did not want Costa's bond pulled. S.A.S.A. Chris Alexy asked Costa, "So the Mayor helped you Ol
in that instance." Costa replied, "Yes, he did. "

THAT evidence indicates that John McGrane sent the letter to Costa's bonding company on 05/08/2006. Charle
Crocini 's letter was sent to the bonding company on 05/16/2006. Costa stated that ifhis construction bond had been pulle
"I would probably cease to be a contractor." Costa stated it would have been difficult for his company to have bee
bonded again. Costa stated that this action by Perez "was a big favor" that kept him in the construction business.

THAT Costa was asked about the documents in the billing package that appeared to indicate the purchased items wer
for the Church Street Garage or Carioca Club when in fact they were used at the Perez residence. Costa stated that this wa
done so that he could charge the expenditures to other jobs as he did not expect to get paid by Mayor Perez. This woul,
have an obvious tax consideration.

THAT Costa stated that Mayor Perez attended various events at the Carioca Club and presented plaques, awards, key
to the city, etc .. to various artists who performed there. This was done at Costa's request. Mayor Perez drank for fre·
during these visits.

THAT Costa stated that on several occasions the City of Hartford was late paying him for work perfoil11ed on Park Stree
and/or he wanted to be paid quicker than the n0l111alprocess. Costa stated on these occasions he contacted Mayor Pere:
aiid asl(edfor Mayor Pere-Z' lie1jJ. -Costa statdthat Mayoi- Perez had the checks issuedto'him right away.

(This is page 24 of a 25 Page Affidavit.)


DATE AND I DATE SIGNED (Affiant)
SIGNATURE
I-/~-o Inspector Michael Sullivar~y'~'
SUBSCRIBED AND SWORN TP BEFORE ME ON (Date) SIGNED (J}JIifge/Gj~rk, Comm. §,up. Ct., Notary
JURAT'
/
/ ,,~j/.~-)..,~~I/ ~<,~~~~:;~/
~;;~.~·;··~e'" 1-.~ -"~i:;~&. < ~

REVIEWED Y'~3ge / Judge Trail Referee DA~E i


---yrc----- Ol(~U /(J -r
ci
(
ARREST· WARRANT AFFIDAVIT INSTRUCTIONS STATE OF CONNECTICUT
CONTINUAT.ION PAGE The jurat is to be completed for each page of the affidavit. SUPERIOR COURT
JD-CR-64a Rev. 10-04 The prosecutorial official and judge/judge trial referee are to date
, C.G.S. § 54-2a and sign or initial each page to indicate that they have reviewed it.;
·Pr:8k. Sec.35~i, 35-2. 36-3

. NAME AND RESIDENCE (Town) OF ACCUSED


Eddie PEREZ 59 Bloomfield Avenue, Hartford, CT COURT TO Hartford
BE HELD AT (Town) 14NO .
IG. A.

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

THA T the affiant believes that probable cause exists to charge Eddie Perez with violating the Connecticut Gener
Statutes §

Bribe Receiving 53a-148


Fabricating Physical Evidence 53a-155
Conspiracy to Fabricate Physical Evidence 53a-155/53a-48

(This is page 25 of a 25 Page Affidavit.)


DATE AND IDATE
SIGNATURE /-/
SUBSCRIBED AND SWORN TQ BEFORE ME ON (Date) SIGNED (JudgeY~erk,<epmm. Sup. Ct..
JURAT
."
.J

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e / Judge Trail Referee


REVISWE~>ro\Tcutor.~91 ~jC;.9I) ".. --.
-- . -.. - -_.j .•..--.- .... <:•.. - .•.. ,---;-:'-. . '-" ./
/ ./
ARREST·WARRANT AFFIDAVIT INSTRUCTIONS STATE OF CONNECTICUT
CONTINUAtiON PAGE The jurat is to be completed for each page of the affidavit. SUPERIOR COURT
JD-CR-64a Rev. 10-04 The prosecutorial official and judge/judge trial referee are to date
, C.G.S. § 54-2a and sign or initial each page to indicate that they have reviewed it.;
Pr.Bk. Sec.u3S-i, 36-2, 36-3

NAME AND RESIDENCE (Town) OF ACCUSED COURT TO BE HELD AT (Town) G. A. NO.


!::ddie PEREZ 59 Bloomfield Avenue, Hartford, CT Hartford 14

AFFIDAVIT
The undersigned affiant, being duly sworn, deposes and says:

THA T the affiant believes that probable cause exists to charge Eddie Perez with violating the Connecticut Gener
Statutes §

Bribe Receiving 53a-148


Fabricating Physical Evidence 53a-155
Conspiracy to Fabricate Physical Evidence 53a-155/53a-48

25
(This is page of a 25 Page Affidavit.)
DATE AND IDATE SIGNED (Affiant)
SIGNATURE Inspector Michael Sulliva~
,/-..-;
JURAT SUBSCRIBED AND ;;WORN Tq BEFORE ME ON (Date)
SIGNED (JU~.£1erk/J;~' ~.~ Ct.,
/-.,/<],~L (I ./'C / '-,;;;/"-t.-/ "L..
DATE
REVIE,WEor:(~r6~7cutor~gl OffiCi.5ll) f~ _, DA~E I
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