Perez

STEP 1 - PEEL AWAY LONG COPIES, THEN SNAP OUT CARBONS STEP 2 - SNAP OUT CARBON FROM REMAINING SHORT COPIES

STATE OF CONNECTICUT SUPERIOR COURT

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STATE OF CONi-.JECTiCUT SUPERiOR COURT·

iNFORMATION JD-CR-71

Rev. 1-03

_Ii'

f/- _ .. I 57".... ATE OF CONNECTICUT fO: Any Proper OffIcer or tne State of Connecticut

GA N°'IDATE . I 0\ !2
By A.UTHORiTY OF THE STATE OF CONNECTICUT, accused. {')(" aff that BPP/V)

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to arrest the body or the within··named

A.. Accused is orderedtb be brought before a clerk or assistant clerk of the Superior CourL 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

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. you are hereby commanded

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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 sameihthe hearing Of said accused; and have said accused here in court for examination. ATTEST

(Offlcer's signature

and Department)

accused and read the

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SEE ADDITIONAL

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ARREST

WA,.RRANT APPLICATION

STATE OF CONNECTICUT SUPERIOR COURT

JD-CR-64EL Rev.10-04C.G.S. § 54-2a. Pro Bk. Sec. 36-1. 36-2. 36-3

FOR COliRT lISE ONLY Supporting Affidavits Sealed

www.jud.state.ct.us

0

DYES AGENCY

NO

NO.

PI07-007 NAME AND RESIDENCE (Town) OF ACCUSED

GANO.

L.UUK I I U ,,~ HELD AT (Town)

14

Hartford

Eddie PEREZ 59 Bloomfield

Avenue, Hartford, CT 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

TYPE/PRINT

AND

NAME

OF PROSECUTING

S.A.S.A. Christopher

SIGNATURE

The undersigned,

AUTHORITY

Alexy

AFltlD'AVIT 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 § 5447d(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:

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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. DATE

AND

SIGNED

'

,

AT (City or Town) NAME OF JUDGE!JUOO£-'fR!Ab-R"l'~.&-~ ON (Date) tt .'" {rif"j Judid8Trlii Referee) ."a.t..,:'.,(Judge! ~, .•••.•. ."...,.,..,"...,. .••.~~'f k:.../(t;{

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ARREST WARRANT AFFIDAVIT CONTINUATION PAGE JD-CR-64a Rev 10-04 C.G.S.§ 54-2.3 Pro Bk. Sec. 35-1, 36-2, 36-3

INSTRUCTIONS The jurat is to be completed for each page of the affidavit. The prosecutorial official and judge/judge trial referee are to date and sign or initial each page to indicate that they have reviewed it.:

STATE OF CONNECTIC,U:r S.UPER,IORCOURT

NAME AND RESIDENCE (Town) OF ACCUSED

Eddie PEREZ

14NO. COURT TOHartford BE HELD AT (Town) /G. A.

59 Bloomfield Avenue, Hartford, CT 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 SIGNATURE

JURAT

IDATE

SIGNED (Affiant)

/ -/$ -0

Inspector Michael SullivanJ~../.

SUBSCRIBED ANDSW9R.1':!TO ~tFORE ME ON (Date) s/' ",;~.,,/

REV(EWEp'(Pr9ie~ytori,af Official) i ' ',/-- .(,/-: /' ,-~ . ...

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SIGNED (Jud~;be3<,

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REVIE;.WED/(Judg,SljJudge Trail Referee C.__ ,.•.. ··?1~'· "-~-~ J'

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Comm. Sup. C,J.,Nota';-yPU~)

ARRESTWARRANT AFFIDAVIT CONrlNUATiON PAGE ,JD-CR-64a

Rev. 10-04

STATE OF CONNECTICUT SUPERIOR COURT

INSTRUCTIONS The jurat is to be completed for each page of the affidavit. 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

COURT TO Hartford BE HELD AT (Town)

'59 Bloomfield Avenue, Hartford, CT

IG. A. 14NO.

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: 2385.00 371.00 1774.63 750.00 1234.80 88.21 1681.68 408.02 5,762.47 2,862.00 2,900.00 20,217.00

Kitchen Countertop 1 BathTOom cabinst 1 Shower door 1 Tile installation 1 Tile materials 1 Grout & miscellaneous 1 Home Depot 1 Metcaf Glass 1 Plimpton & Hills 1 Donald Sullivan' 1 Lump sum labor Overall Total

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

DATE

3 ora

AND

25 Page Affidavit.) IDATE

SIGNED (Affiant)

1-/3-0

S lGNATURE

JURAT ~~ ~-

SUBSCRIBED

AND SWORN TO BEFORE

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ME ON (Date) SIGNED(~;,~gel,:fl=". ..,~K'~/j' ~.;>,

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RE yiEWJ!: [;i'Wrqs'ecutori pfOfficial ) "1.

Inspector Michael Sullivaf!Zi

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DATE i'" .~..;,?

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Notary P. ~.

Judge Trail Referee

ARREST w ARRAN1:AFftf)A\tJT~ CONTINUATION PAGE JD-CR-64a

Rev

10-04

C.GS § 54-2a

lNSTRUCTIONS The jurat is to be completed for each page of the affidavit. The prosecutorial official and judge/judge trial referee are to date and sign or initial each page to indicate that they have reviewed it.;

STATE OF CONNECTICUT SJjPER!OR CO!iRT

Pro Bk. Sec. 35-1, 36-2, 36-3 NAME AND RESIDENCE

(Town) OF ACCUSED

Eddie PEREZ

COURT TO Hartford BE HELD AT (Town)

59 Bloomfield Avenue, Hartford, CT

/G. A. 14NO.

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

DATE AND SIGNATURE

of a 25 Page Affidavit.) SIGNED

I DATE

Inspector Michael Sulliva.!1tu SIGNED

.

-

(p~1ecutorialpff~efal)

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(Judge! Cler~, Comm. SUR- Ct., N~ry

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AR:REST'WARRANT AFFIDAVIT CONTINUATiON PAGE ,JD-CR-64a

Rev. 10-04

C.G.S. §54-2a

INSTRUCTIONS The jurat is to be completed for each page of the affidavit. The prosecutorial official and judge/judge trial referee are to date and sign or initial each page to indicilte thilt they have reviewed it.;

STATE OF CONNECTICUT SUPERIOR COURT

Pro Bk. Sec. 35-1, 36-2, 36-3 NAME AND RESIDENCE

(Town) OF ACCUSED

Eddie PEREZ

59 Bloomfield

Avenue,

Hartford,

COURT TO Hartford BE HELD AT (Town)

CT

IG. A. 14NO.

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

DATE AND SIGNATURE

JUFAT

a 25 Page Affidavit.) IDATE

SIGNED (Affiant)

/-/3 -0 SUBSCRIBED

AND SWORN TO BEFORE ME ON (Date)

i-'/,'; . :,c t./

Inspector Michael Sullival]h SIGNED (Ju99,~Ci1J1'

~omm.

S,Y.P-'Ct., N6tary ~iC)

.~.""',.,~v~~::~~~ ~:.~
/ Judge Trail Referee

ARREST WARRANT AFFIDAVIT CONTINUATION PAGE JD-CR-64a

C.G.S.

Rev

10-04

§ 54-2a

INSTRUCTIONS The jurat is to be completed for each page of the affidavit. The prosecutorial official and judge/judge trial referee are to date and sign or initial each page to indicate that they have reviewed it.;

STATE OF CONNECTICUJ S.UPERIORCO,!JRT

Pro Bk. Sec. 35-1, 36-2, 36-3 NAME AND RESIDENCE

(Town) OF ACCUSED

Eddie PEREZ

COURT TO Hartford BE HELD AT (Town)

59 Bloomfield Avenue, Hartford, CT

IG. A. 14NO.

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

DATE AND SIGNATURE

JURAT

a 25 Page Affidavit.) SIGNED (Affiant)

IDATE

/-/3-0 SUBSCRIBED

AND SWORN

Inspector Michael SullivanJ.?1.: TO BEFORE

ME ON (Date)

SIGNED (JU9~/

Clerk, Comm. SUP,.Ct., Notary Pu

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Judge Trail Referee

- ARREST WARRANT AFFIDAVIT CONTINUAT.ION PAGE JD-CR-64a Rev. 10-04 C.G.S. § ;i4-2a Pro Bk. Sec. 3;)-1,36-2,36-3 NAME AND RESIDENCE

INSTRUCTIONS The jurat is to be completed for each page of the affidavit The prosecutorial official and judge/judge trial referee are to date and sign or initial each page to indicate that they have reviewed it.;

STATE OF CONNECTICUT SUPERIOR COURT

(Town) OF ACCUSED

Eddie PEREZ

COURTTO

59 Bloomfield Avenue, Hartford, CT

BE HELD Hartford

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

DATE AND SIGNATURE

a 2;) Page Affidavit) IDATE

SIGNED

Inspector Michael Sullivan..7u SIGNED

RE\(IEWE6(Pr9~fi~utofjal . 'r. ( ... --."

( __._/.I

(Affiant)

o,fficial) ! ~~

i .._ .. c__ . ·t.-.-/

DATE

/-~! ../-;:: ,<)

(Jud~,.(;le~5<'

Comm. Sup. Ct.,

_~:.:/;? ,~.... t:;~t,·~i..~_.,.,,...~v.>"£.'

~?rar~t~ J.-- ...-"-

:

! . !()qr

ARREST WARRANT AFFIDAVIT CONTINUATION PAGE JD-CR-64a

Rev

10-04

C.G.S. § 54-2a Pro Bk. Sec. 35-1, 36-2, 36-3 NAME AND RESIDENCE

STATE OF CONN6CTIC.U:r SUPERIOR COURT

INSTRUCTIONS The jurat is to be completed for each page of the affidavit. The prosecutorial official and judge/judge trial referee are to date and sign or initial each page to indicate that they have reviewed it;

(Town) OF ACCUSED

Eddie PEREZ

COURT TO Hartford BE HELD AT (Town)

59 Bloomfield Avenue, Hartford, CT

IG. A. 14NO.

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

DATE AND SIGNATURE

a 25 Page Affidavit.)

I DATE

SIGNED

(Affiant)

Inspector Michael SUllivan~~/,~ JURAT

SIGNED

(~.~~~e'7c.17rk:comm:.,~~'_

>/-:"~,../

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

:•.;,./,?

REVIEW7:'::~;¥.:.~~_L:;I..~.9ge Trail Referee

l

?;l

~t., Notary Pu

••.... / l. ..'~'

.>

DATE, . / ._. () f f 2,1."1/ () "1

-ARREST WARRANT AFFIDAVIT CONTJNUATI,ON PAGE JD-CR-64a

Rev. 10-04

C.G.S. § 54-2a Pro Bk:'Sec. 35-1. 36-2, 36-3 NAME AND RESIDENCE

INSTRUCTIONS The jurat is to be completed for each page of the affidavit. The prosecutorial official and judge/judge trial referee are to date and sign or initial each page to indicate that they have reviewed it.;

STATE OF CONNECTICUT SUPERIOR COURT

(Town) OF ACCUSED

Eddie PEREZ

59 Bloomfield

Avenue,

Hartford,

COURT TO Hartford BE HELD AT (Town)

CT

IG. A. 14NO.

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, following: 3/4 inch 4'x8' Sanded Pine Plywood

was attached to the bill. It was found to be for the

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 DATE AND I DATE

This is page

Affidavit.)

SIGNATURE

1-/3 -0 SUBSCRIBED

I

SIGNED (Affiant)

AND SWORN TQ BEFORE

/{:J L 7..-T--

REviEWED

-,------._

•.

!Prosecutoriaf

Official)

~_.._----~(~.) (._,.~?/·f~._~.(

ft':

Inspector Michael SUllivan..7u?"A"p ME ON (Date)

SIGNED (J~gei CI~~~'EComm.~up. Ct., NQiary"liC) ~,.::~:/ ..~ ~~~::>t1 ) ..-'- :(~..- ~, ,&-I~,~" '--r..."

~!

REVIEW.§QjJt,!..~ge / Judge Trail Referee " ,.' 1t1 /'"...... ------L....-;"j ~.

ARREST WARRANT AFFIDAVIT CONTINUATION PAGE JD-CR-64a

Rev. 10-04

C-.-G.S. § 54-2a Pro Bk. Sec. 35-1, 36-2, 36-3 NAME AND RESIDENCE

STATE OF CONNECTICUT SUPERIOR COURT

INSTRUCTIONS The jurat is to be completed for each page of the affidavit. The prosecutorial official and judge/judge trial referee are to date and sign or initial each page to indicate that they have reviev·;ed it.;

(Town) OF ACCUSED

Eddie PEREZ

COURT TO Hartford BE HELD AT (Town)

59 Bloomfield Avenue, Hartford, CT AFFIDAVIT

The undersigned affiant, being duly sworn, deposes and says: 2-

12"

1-114"

4'x 8' sheet rockl drywall 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

DATE AND SIGNATURE

Page Affidavit.)

I DATE

SIGNED (Affiant)

1-/3-09'.

-----------------

JURAT /

SUBSCRIBED

REVI Ev{E~«P:Os~cutoria( ..•.•.•...._ ,if', .~.,.j '.... "

bffjcial)

AND S':"?RN .} ...-.~. ,

f

TO<ElEFORE ME ON (Date)

Inspector Michael Sulliva'lTuSIGNED (Jud~;t1.furk,

.

~

9:,\Tlm SUP/C.r, No ary P ./'''..:-;/';-", ~:~:if/'~'~t,,-.~;," ~,~ ~ ..-,t.

REVIEWED (Judge / Judge Trail Referee /'--::{..--i .--'~

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'-"""

.

IG. A. 14NO.

ABgEST, WARRANT AFFIDAVIT CONTINUAT.ION PAGE JD-CR-64a Rev. 10-04 eG.s. § 54-2a Pro Elk. Sec. 35-1, 36-2, 36-3 NAME AND RESIDENCE

INSTRUCTIONS The jurat is to be completed for each page of the affidavit. The prosecutorial official and judge/judge trial referee are to date and sign or initial each page to indicate that they have reviewed it.;

STATE OF CONNECTICUT SUPERIOR COURT

(Town) OF ACCUSED

Eddie PEREZ

59 Bloomfield Avenue, Hartford, CT

COURT TO Hartford BE HELD AT (Town)

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

DATE AND SIGNATURE

a 25 Page Affidavit.)

IDATE

. __-0 SUBSCRIBED

AND SWORN

/i --I --, REVIEWEQ(Pr6secwtorip'i ,

:.',f.~'

.

? ,

Offjcial) .

i

TO BEFORE

L'

ME ON (Date)

14NO. IG. A.

ARREST WARRANT AFFIDAVIT CONTINUATION PAGE JD-CR-64a C".G:S".

Rev. 10-04

§ 54"-2a

STATE OF CONN6CTIGUT SUPERIOR COURT

INSTRUCTIONS The jurat is to be completed for each page of the affidavit. The prosecutorial official and judge/judge trial referee are to date 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

COURT TO Hartford BE HELD AT (Town)

59 Bloomfield Avenue, Hartford, CT

IG. A. 14NO.

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 for brass) $350.40. THAT a Home Depot receipt, dated June 13,2005, ITEM NOT ON FILE

& Hills

- (chrome to be exchanged late

for $99.86, was found to be for the following:

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

DATE AND

Page Affidavit.) SIGNED

DATE

/-/.'5 -6'7 .

SIGNATURE ./ i 1"/ JURAT .~. ,

REVIEWEf1

,SUBSCRIBED ~

(I?(~secuto~jal/)ffiSjal)

' __._':(".'> ',_.

r

.

!

\"'.J /• .•.SW.o."RN " !>.,.~ J' ' .... TqB.EFORE ,. AN?

(Affiant)

,

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

SIGNED ME ON (Date)

.j

(Jupge'/ ClerK,]Comm.

'''<>/

"""j:'~'{\

REVIEW§.Q_;-4l~~~3dge

C.·ilt

Sup. Ct,., Notary,8

;"",,'f""l-~.

Trail Referee

""~ .

ARREST WARRANT AFFIDAVIT CONTINUATION PAGE JD-CR-64a

Rev. 10-04

C.G:S". §" 54.:.2a Pro Bk. Sec. 35-1, 36-2, 36-3 NAME AND RESIDENCE

STATE OF CONN6GTICHT SUPERIOR COURT

INSTRUCTIONS The jurat is to be completed for each page of the affidavit. The prosecutorial official and judge/judge trial referee are to date and sign or initial each page to indicate that they have r8vie\.A'!ed it.;

(Town) OF ACCUSED

Eddie PEREZ

COURT TO Hartford BE HELD AT (Town)

59 Bloomfield Avenue, Hartford, CT

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 for brass) $350AO. THAT a Home Depot receipt, dated June 13,2005, ITEM NOT ON FILE

& Hills

- (chrome to be exchanged late

for $99.86, was found to be for the following:

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 12 of a 25

(This is page

DATE AND SIGNATURE

Page Affidavit.)

IDATE

SIGNED

/-/'"5 -07'.

SUBSCRIBED ."

I ~,~~~I }·,3 ~.'{,

~

"

ANQ SWORN TQ BEFORE ME ON (Date)

(Affiant) "

(Jupg4/ ClerK,)Comm.

Sup.

--"

:""~"

C,"",.·

q, Notary

, ,.j"~/~~:~;:'/ ·.~.~.e'..I'~~~,..t~\ ?:s:~",;·,·;o·:;·/(r ;;.•.

REVIEWED , : ...(l?r<;lsecutorial ~: ':}- ,Officjal) ,

"' ,.,'.'~< _,_j_

,

Inspector Michael Sulliva.ntH..$./~ SIGNED

REVIEW~.Jf~~~~dge

Trail Referee

P-

_",~~.;

ARREST ,WARRANT AFFIDAVIT CONTINUATION PAGE JD-CR-64a Rev. 10-04 C.G.S. § 54-2a Pr. Bk. Sec. 35-1, 36-2, 36-3 NAME AND RESIDENCE

(Town) OF ACCUSED

Eddie PEREZ

STATE OF CONNECTICUT SUPERIOR COURT

INSTRUCTIONS The jurat is to be completed for each page of the affidavit. The prosecutorial official and judge/judge trial referee are to date and sign or initial each page to indicate that they have reviewed it.;

COURT TO BE HELD AT (Town)

Hartford

59 Bloomfield Avenue, Hartford, CT

G. A. NO.

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. 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

DATE AND SIGNATURE

JURAT

a 25 Page Affidavit.)

I DATE

SIGNED (Affiant)

Inspector Michael Sulliv~-:./, SIGNED (Ju~€i/

./-

._..i>.~::.1>

REVIS\NW /'

8t.,~.t~ry,

4.~:"/:'>~'~:""'-~""-'-"'''' ~:."

(Judge / Judge Trail Referee

Ji...-r" -",---

.... _~{t/

Clyrk, Comm. Sup

L.V~:;:r;.>1';'··i

Ii>

MI

ARREST WARRANT AFFIDAVIT CONTINUATION PAGE JD-CR-64a

CGS

Rev. 10-04

§ 54-2a

STATE OF CONNEGTIC.lJJ SUPERIOR ,.. COURT

INSTRUCTIONS The jurat is to be completed for each page of the affidavit. The prosecutorial official and judge/judge trial referee are to date .?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

COURT TO Hartford BE HELD AT (Town)

59 Bloomfield Avenue, Hartford, CT

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

DATE AND SIGNATURE

JURAT r----.-;---r

Page Affidavit.)

I DATE

SIGNED (Affiant)

/-/3-0

SUBSCRIBED

AND SWORN "

,/

~

REVlEW f,zl;i(Pro~ecut9Jia

:;. ...~!.~~: .._":,~/)C..".~

(

~Dffi ci a I) L.

"'"~.

/

..

,:

Inspector Michael Sulliva!:!T0

TO,BEFORE 1... ~.

ME ON (Date)

{

.. >"c.:;>' DATE

/ ;~-/,~":.:.~) --

:./,~

SIGNED (Jud.ge/ Clerk, Comm. Sup. Ct., NO~ry Pu

'-,

,>-<,£::.<·t·.

~._~

t •.

• f ~..--RE~...,t.Q."E~_.~JUd9c:!~Udge Trail Referee

,~,I DAT~2 '-.3' \j

...,-, f~ /v l~,(t", I

ARREST-WARRANT AFFIDAVIT CONTINUAT~ON PAGE JD-CR-64a

The jurat is to be completed for each page of the affidavit. The prosecutorial official and judge/judge trial referee are to date and sign or initial each page to indicate that they have reVie\A!ed it.;

Rev. 10-04

C.G~·S. § 54-2a Pro Bk. Sec. 35-1, 36-2, 36-3 NAME AND RESIDENCE

STATE OF CONNECTICUT SUPERIOR COURT

INSTRUCTIONS

(Town) OF ACCUSED

Eddie PEREZ

COURT TO Hartford BE HELD AT (Town)

59 Bloomfield Avenue, Hartford, CT

IG. A. 14NO.

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

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ARREST WARRANT AFFIDAVIT CONTINUATION PAGE JD-CR-64a

Rev. 10-04

C.G,S. § 54-2a Pro Bk. Sec. 35-1, 36-2, 36-3 NAME AND RESIDENCE

(Town)

STATE OF CONNECTICUT $UPE~IOR CQURT

INSTRUCTIONS The jurat is to be completed for each page of the affidavit. The prosecutorial official and judge/judge trial referee are to date and sign or initial each page to indicate that they have reviewed it.;

OF ACCUSED

Eddie PEREZ

COURT TO Hartford BE HELD AT (Town)

59 Bloomfield Avenue, Hartford, CT

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

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ARREST 'WARRANT AFFIDAVIT CONTINUAnON PAGE JD-CR-64a

C.G.S.

Rev. 10-04

§ 54-23

STATE OF CONNECTICUT SUPERIOR COURT

INSTRUCTIONS The jurat is to be completed for each page of the affidavit. The prosecutorial official and judge/judge trial referee are to date 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

COURT TO Hartford BE HELD AT (Town)

59 Bloomfield Avenue, Hartford, CT

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

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ARREST WARRANT AFFIDAVIT CONTINUATION PAGE

INSTRUCTIONS The jurat is to be completed for each page of the affidavit. The prosecutorial official and judge/judge trial referee are to date and sign or initial each page to indicate that they have revie\ved it;

JD-CR-64a Rev. 10-04 C.G.S. § 54-2a Pre Bk. Sec. 35-1, 36-2, 36-3 NAME AND RESIDENCE

(Town) OF ACCUSED

Eddie PEREZ

STATE OF CONN6CTIClH SUPERJORCo.URT

COURT TO BE HELD AT (Town)

G. A. NO.

Hartford

14

59 Bloomfield Avenue, Hartford, CT 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 verified this again today about 10 minutes ago. USA Contractors will forward out communications to U , his office. Charles Crocini's offices. "

I

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 18 of a

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-ARRESTWARRANT AFFIDAVIT CONTINUATION PAGE JD-CR~64a Rev '10-04 G.GS. § 54.-2a Pro Bk. Sec. 35-1, 36-2, 36-3 NAME AND RESIDENCE

INSTRUCTIONS The jurat is to be completed for each page of the affidavit. The prosecutorial official and judge/judge trial referee are to date and sign or initial each page to indicate that they have reviewed it.;

STATE OF CONNECTICUT SUPERIOR COURT

(Town) OF ACCUSED

59 Bloomfield Avenue, Hartford, CT

Eddie PEREZ

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

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The jurat is to be completed for each page of the affidavit. The prosecutorial official and judge/judge trial referee are to date and sign or initial each page to indicate that they have reviewed it.;

Rev. 10-04

C.G.S. § 54-2a Pr. Bk. Sec. 35-1, 36-2, 36-3 NAME AND RESIDENCE

STATE OF CONNECTIC~T SUPERIOR COURT

INSTRUCTIONS

CONTINUATION PAGE

(Town) OF ACCUSED

Eddie PEREZ

COURT TO Hartford BE HELD AT (Town)

59 Bloomfield Avenue, Hartford, CT

IG. A. 14NO.

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 DATE

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AKKt:~ I ,WAKKAN r AFFIDAVIT CONTINUATION PAGE

STATE OF CONNECTICUT SUPERIOR COURT

INSTRUCTIONS The jurat is to be completed for each page of the affidavit The prosecutorial official and judge/judge trial referee are to date and sign or initial each page to indicate that they have reviewed it;

JD-CR-'64a Rev.'10-04 ·C.G.S. § 54-2a .. Pr. Bk. Sec. 35-1, 36-2, 36-3

NAME AND RESIDENCE (Town) OF ACCUSED

Eddie PEREZ

14NO. COURT TOHartford BE HELD AT (Town) IG. A.

59 Bloomfield Avenue, Hartford, CT 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 SIGNATURE

SIGNED (Affiant)

-09 .

Inspector Michael Sullivan '.

SUBSCRIBED AND SWORN TO BEFORE ME ON (Date)

JURAT

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CONTINUATION PAGE JD-CR-64a

Rev. 10-04

C.G.S. § 54-2a Pro Bk. Sec. 35-1, 36-2, 36-3 NAME AND RESIDENCE

STAI E OF CONNE.CTIC~T SUPERIOR COURT

INSTRUCTIONS The jurat is to be completed for each page of the affidavit. The prosecutorial official and judge/judge trial referee are to date and sign or initial each page to indicate that they have reviewed it.;

(Town) OF ACCUSED

Eddie PEREZ

COURT TO Hartford BE HELD AT (Town)

59 Bloomfield Avenue, Hartford, CT

IG. A. 14NO.

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. Mayor Perez ever intervening on behalf of another contractor for payment.

Morrison could not recal

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 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

)f work

22 of a 25 DATE AND IDATE SIGNATURE

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, ARREST. WARRANT AFFIDAVIT CONTINUAT,ION PAGE JD-CR-64a

Rev. 10-04

C.G.S. § 54-2a Pro Bk. Sec. 35-1, 36-2. 36-3 NAME AND RESIDENCE

STATE OF CONNECTICUT SUPERIOR COURT

INSTRUCTIONS The jurat is to be completed for each page of the affidavit. The prosecutorial official and judge/judge trial referee are to date and sign or initial each page to indicate that they have reviewed it.;

(Town) OF ACCUSED

Eddie PEREZ

COURT TO Hartford BE HELD AT (Town)

59 Bloomfield Avenue, Hartford, CT

IG. A. 14NO.

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 thCity." Costa was asked what would happen ifhe had not done Mayor Perez's work for free. Costa stated he believed would have been "persona non grata" al?-dnot looked upon favorably by the powers that be in the City. Costa stated 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. 11<

11<

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 DATE AND SIGNATURE

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I DATE

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ARREST WARRANT AFFIDAVIT CONTINUATION PAGE JD-CR-64a

Rev. 10-04

eG.s" § 54-2a

STATE OF CONNECTICUT SUPERJOR COURT

INSTRUCTIONS The jurat is to be completed for each page of the affidavit. The prosecutorial official and judge/judge trial referee are to date 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

COURT TO Hartford BE HELD AT (Town)

59 Bloomfield Avenue, Hartford, CT

IG. A. 14NO.

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

DATE AND SIGNATURE

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ARREST· WARRANT AFFIDAVIT CONTINUAT.ION PAGE JD-CR-64a Rev. 10-04 , C.G.S. § 54-2a ·Pr:8k. Sec.35~i, 35-2. 36-3 . NAME AND RESIDENCE

STATE OF CONNECTICUT SUPERIOR COURT

INSTRUCTIONS The jurat is to be completed for each page of the affidavit. The prosecutorial official and judge/judge trial referee are to date and sign or initial each page to indicate that they have reviewed it.;

(Town) OF ACCUSED

Eddie PEREZ

COURT TO Hartford BE HELD AT (Town)

59 Bloomfield Avenue, Hartford, CT

IG. A. 14NO .

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

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ARREST·WARRANT AFFIDAVIT CONTINUAtiON PAGE JD-CR-64a

, C.G.S. Pr.Bk.

Rev. 10-04

§ 54-2a Sec.u3S-i,

STATE OF CONNECTICUT SUPERIOR COURT

INSTRUCTIONS The jurat is to be completed for each page of the affidavit. The prosecutorial official and judge/judge trial referee are to date and sign or initial each page to indicate that they have reviewed it.;

36-2, 36-3

NAME AND RESIDENCE

(Town) OF ACCUSED

!::ddie PEREZ

COURT TO BE HELD AT (Town)

G. A. NO.

Hartford

14

59 Bloomfield Avenue, Hartford, CT 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 DATE AND SIGNATURE

(This is page

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IDATE

Inspector Michael Sulliva~

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