Investigation and
Prosecution of a
Complex Financial Case
Ivan Orton
Senior Deputy Prosecuting Attorney
Economic Crimes Unit
King County Prosecuting Attorney
ivan.orton@kingcounty.gov 206 296-9082
Today’s Agenda


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Background on two recent cases that went to
trial
Discuss the challenges these cases presented
when preparing for trial
Demonstrate how evidence was produced at trial
CASES


The jail bookkeeper who embezzled from work
release inmates
The plundering of Frances Taylor’s assets
Jail Bookkeeper
Former jail bookkeeper charged with
stealing from inmates
Posted by Jennifer Sullivan
A former bookkeeper at the King County Jail was
charged Monday with 22 counts of seconddegree theft for allegedly stealing money from
inmates who were serving their time on work
release, according to charging documents filed
in Superior Court.
William Findley
State Auditor’s Report
Process
$
$
Bookkeeping
Check for Cash Scheme



Unrecorded inmate check would be included in
deposit
Equal amount of cash would be removed from
deposit
Oh, if it were only that simple
Auditor Identified 66 Such
Transactions in Audit Period
(one year)




I eliminated all that were not pristine examples
Left with 39
17 were beyond the statute of limitations
The other 22 were charged
Here Was My Problem

How in the world can I present this to a jury so
they will
Understand it
 Not be totally bored

Citizenship Award
Legal Theory
Three Theories of Theft
 By
Deception
 By Taking
 By Exertion of Unauthorized Control
Exertion of Unauthorized
Control
Having any property or services in one's possession, custody or
control
as bailee, factor, lessee, pledgee, renter, servant, attorney,
agent, employee, trustee, executor, administrator, guardian,
or officer of any person, estate, association, or corporation,
or as a public officer, or person authorized by agreement or
competent authority to take or hold such possession,
custody, or control
to secrete, withhold, or appropriate the same to his or her
own use or to the use of any person other than the true
owner or person entitled thereto
Essence


Hold property in a capacity which limits your
authority
Exceed that authority
Capacity

Most Common Capacities in Elder Fraud Cases
Attorney (Power of Attorney)
 Other Listed (Guardian, Trustee)
 Agreement


Crucial Concept of Fiduciary
A Lawyer Will Always Object
Any Kind of Objection
POA - What’s the Law
Power of Attorney
A person acting under authority of a Power of
Attorney does not have the power to make, amend,
alter or revoke the principal’s wills, and does not have
the power, unless specifically provided otherwise in the
document, to make gifts of property owned by the
principal.
RCW 11.94.050
POA - What’s the Law
Power of Attorney
An attorney-in-fact is an agent to whom the principal has
given authority to act in his or her stead for the purposes set
forth in the power of attorney. In that role, the agent becomes
a fiduciary who is bound to act with the utmost good faith
and loyalty and to fully disclose all facts relating to his
interest in and his actions involving the affected property; the
agent must also deliver all benefits derived from or
inuring to the property from the agent's breach of the
fiduciary relationship to the principal.
Bryant v. Bryant, 125 Wash.2d 113, 118-19, 882 P.2d 169 (1994)
Crisman v. Crisman, 85 Wash.App. 15, 22, 931 P.2d 163 (1997) (citing Moon v. Phipps, 67 Wash.2d 948, 956, 411 P.2d 157
(1966)).
In re Estate of Palmer, 145 Wash.App. 249, 263, 187 P.3d 758 (2008)
POA - What’s the Law
Power of Attorney
Inherent in the fiduciary relationship between principal
and attorney-in-fact is the duty to account for the
assets managed by the attorney-in-fact.
Crisman v. Crisman, 85 Wash.App. 15, 22, 931 P.2d 163 (1997)
In re Estate of Palmer, 145 Wash.App. 249, 264, 187 P.3d 758 (2008)
TRUSTEE - What’s the Law
As used in these instructions, the word “trust” means a
fiduciary relationship in which one person holds the
property of another person, subject to the obligation to
keep or use that property for the benefit of the other
person. As used in these instructions, the word
“trustee” means the individual who holds the trust
property for the benefit of the other person.
Restatement of Trusts, Second, § 2
Bogert, Trusts and Trustees, 2nd Edition § 1
What is a Fiduciary
A fiduciary relationship exists where confidence is
reposed on one side and resulting superiority and
influence on the other. Any person whose relation
with another is such that the latter justifiably
expects his welfare to be cared for by the former
occupies a fiduciary position.
Tucker v. Brown, 199 Wash. 320, 331, 92 P.2d 221 (1939)
Salter v. Heiser, 36 Wn.2d 536, 551, 219 P.2d 574 (1950)
Moon v. Phipps, 67 Wn.2d 948, 955, 411 P.2d 157 (1966)
Liebergesell v. Evans, 93 Wn.2d 881, 889-90, 613 P.2d 1170 (1980)
Restatement of Contracts, §472(1)(c), & Comment C at 898 (1932)
Where does Fiduciary Concept Fit
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Many of the named relationships (attorney, agent,
trustee, executor, administrator, guardian) explicitly
carry with them a legal fiduciary duty.
Even if not acting in one of these capacities, one can
have an in-fact fiduciary relationship.
A fiduciary has certain limits on their authority.
If one hold property by agreement, as a fiduciary, the
limits on a fiduciary define the scope of authorized
control
Exceeding that authority, in the right amount and with
the requisite intent to deprive, is theft
Fiduciary Law
A fiduciary, in handling another’s (the
principal’s) property, must exercise the utmost
good faith, disclose fully all facts relating to his
interest in and his actions affecting the property
involved in the fiduciary relation, and must use
his principal’s property solely for his
principal’s benefit.
Moon v. Phipps, 67 Wn.2d 948, 954-56, 411 P.2d 157 (1966)
Fiduciary Law
A fiduciary may not exert undue influence
over the other party in the fiduciary relationship
in order to obtain a gift from the person.
Doty v. Anderson, 17 Wn. App. 464, 471, 563 P.2d 1307 (1977)
Fiduciary Law

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Whether a gift to a fiduciary is the product of undue
influence is a factual question to be determined in light
of the following factors:
the donor’s age and mental condition;
her prior intentions and concerns as to the disposition
of her property,
the size of the gift and the financial condition in which
it leaves the donor;
her knowledge and understanding of the terms of the
gift, and
the presence or absence of independent advice to the
donor prior to the gift.
McCutcheon v. Brownfield, 2 Wn. App. 348, 356-59, 467 P.2d 868
(1970)
Fiduciary Law
Fiduciary duties do not arise when the agent learns of
his legal obligations arising from the agency
relationship. Rather, a fiduciary relationship arises
when the agent exercises dominion and control
over the principal's property sufficient to alienate
the principal's right to the property.
Crisman v. Crisman, 85 Wash.App. 15, 22, 931 P.2d 163 (1997) (citing
Moon v. Phipps, 67 Wash.2d 948, 955-56, 411 P.2d 157 (1966))
In re Estate of Palmer, 145 Wash.App. 249, 263, 187 P.3d 758 (2008)
Fiduciary Law



These instructions were given in the Tyrone Dash case
CAUTION: These instructions are an issue on appeal
Well . . . Maybe not so much
Issues on Appeal



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
The Fiduciary Instructions
The “Good-Faith-Claim-of-Title” Defense
The Frances Taylor Videotape and the
Confrontation Clause
The “Aggravating Factors” instruction (the
Bashaw issue)
The Statute of Limitations Issue
The Fiduciary Instructions





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Defense Argument: Unprecedented to use Law
from Civil Cases as basis for Criminal
Instructions
Assault
Living with a Prostitute
Proximate Cause
Securities Fraud
theft
The “Good-Faith-Claim-of-Title”
Defense




Defense Argument: It’s Good-Faith-Claim-ofRight or Entitlement, not Title
Look at the word
Self Help is Not Included
Scenario intended for
The Frances Taylor Videotape and
the Confrontation Clause






Crawford and the Change in the Law in 2004
Defense: This is Testimonial
Me: Footnote 9 in Crawford
Court: Was She a Witness for You?
I-5 North/I-5 South, 5th Ave. S/5th Ave. N.
Subsequent cases all involved truth of matter
asserted
The “Aggravating Factors”
instruction (the Bashaw issue)




9 months later
Unanimity
Waived?
Lots of Questions but Hands are Tied
The Statute of Limitations Issue




Why do Prosecutors only Make Love from the
Bottom Position?
Statute of Limitations
Continuing Crime
Didn’t ask that Jury be Instructed they Must
Find at Least One Criminal Act within Statute
of Limitations
The Concern:
Good Shape on First Three Issues
 Might Lose on Bashaw Issue, but . . .
 Great Risk of Reversal on Statute of Limitations
Issue
BUT
 If We Could Win the First Three Issues it
Would Be a Major Victory

The Decision (Monday)





Reversed on Statute of Limitations – Remanded
for a New Trial
Bashaw – Deferred to Supreme Court
Decided Confrontation Issue on Narrow
Grounds But Badmouthed our Theory (5th Ave.
S.)
Completely Ignored Important Issues of
Fiduciary Instructions and Claim of Title Issues
Meeting Tomorrow to Decide
Organization


Bates Stamp?
Index to Bates (Outline rather than specific
documents)
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Master the Detail
Bank Transactions
Credit Card Transactions
Here Was My Problem

How in the world can I present this to a jury so
they will
Understand it
 Not be totally bored

William Findley Trial



Four Auditors involved
Two on Maternity Leave
Two had left the Auditor’s Office and couldn’t
be located
William Findley Trial

Even if I could find them:
How would I use the Audit Report
 It was almost incomprehensibly complex
 As with most audit reports, it identified system
weaknesses that allowed thefts to go undetected

William Findley Trial

Other Witnesses
Findley Supervisor who detected initial problem
 Her Supervisor who referred to auditor
 Internal Investigations Sgt who compiled material
for auditor
 Successor II Sgt who received audit report and
reviewed it

William Findley Trial


One Week Before Trial – An Epiphany
There were four documents for each transaction







History of Drawer Report
Deposit Slip
Item in deposit, not in Report
Inmate account
These four documents, when understood, largely spoke
for themselves
How could I introduce and explain these documents?
How could the jury keep track when shown 39 x 4
(156) individual documents?
William Findley Trial


The answer to the first question was Michael
Maude
The answer to the second question was:
Give the jury a roadmap
 The old shampoo instructions “Lather, Rinse,
Repeat”, i.e.

Explain
Explain
Explain
Explain
Explain
Explain
Explain
Work from the Simple
To the Complex
Johnson Manufacturing
1019
Oct. 15, 2010
Pay to KC Work Release_______________ $100.00
One Hundred & 00/100____________ __
Dollars
Bank of America 19/2
Jim
Memo: Bob Smith
Currency
Coins:
__$100.00_
__$ 40.00_
--------------------------------___19/2__ ____100.00__
Johnson, Sr.
Smith Construction
3088
Oct. 14, 2010
Pay to KC Work Release_______________ $200.00
Two Hundred & 00/100____________ __
Dollars
___24/3__ ____200.00__
_________
____________
72/19
60.00
_________ ____________
_________ ____________
Chase Manhattan 24/3
Charles
Memo: Bob Smith
Smith
_________ ____________
_________ ____________
_________ ____________
_________ ____________
_________ ____________
_________ ____________
_________ ____________
Arnold Grocery
_________ ____________
3088
Oct. 14, 2010
Pay to KC Work Release_______________ $60.00
Sixty & 00/100____________ __
Dollars
_________ ____________
_________ ____________
Key Bank 72/19
Memo: James Evans
Arnold
Total
Robert
__________________
$400.00
Total
$400.00
Sgt. Maude




Had reviewed audit report
Had examined the documents for each
transaction and had recreated each transaction
Together with other witnesses, could lay
foundation for each document
Could explain each transaction
Road Map
CHARGED COUNTS
Count
Missing Cash
Extra Checks
Johansen, Jodi Macko
Thompson, Bryan Daniel
Mooney, Laurie A.
Moore, Lynette Alison
O'Neill, Michael Charles
Mooney, Laurie A.*
Villalovos, Lori Mae
$300.00
$850.00
$375.00
$400.00
$537.00
$881.50
12
13
McMillan, Brent G.
Goodwin, Eugene E.*
Hall, Randy L.
Bedell, Teresa L. aka
Butterfield, Elizabeth
24-May O'Rielly-Williams, Khalila
25-May Cossette, Peter L.
$1,369.90 - $1,069.90
$850.00
$375.05 (error of .05)
$479.50 - $400.00
$287.00
$250.00
$1,442.00 - $642.00 & $450.00
(undeposited)
$681.50
$200.00
$1,000.00
$500.00
14
15
16
17
18
19
20
21
22
4-Jun
5-Jun
18-Jun
20-Jun
22-Jun
3-Jul
18-Jul
26-Jul
6-Aug
1
2
3
4
5
7
8
10
11
Date
8-Feb
13-Feb
28-Feb
1-Mar
8-Mar
8-Mar
27-Mar
Inmate
3-Apr
3-Apr
4-May
11-May
Barre, Gregory G.
DelGadillo, Caesar
Loan, Richard S.
Duncan, Emanuel C.
Lee, Eu
King, Gary Ralph
Russell, Barbara Ann
Nguyen, Sanh Thi
Suh, Kee Won
$350.00
$1,000.00
$500.00
$625.00
$989.20
$439.00
$359.25
$325.00
$300.00
$319.90
$428.40
$477.00
$400.00
$500.00
$600.00 + $25.00
$1,189.20 - $200.00
not deposited
$439.00
$359.25
$325.00
$300.00
$320.00 (error of $.10)
$214.20 + $214.20
$477.00
$400.00
$1,000.00 + $500.00 Money Order
Road Map
Date
17-Oct
17-Oct
27-Oct
13-Nov
17-Nov
4-Dec
8-Dec
8-Dec
13-Dec
3-Jan
9-Jan
12-Jan
22-Jan
30-Jan
14-Feb
15-Mar
21-Mar
27-Mar
8-May
UNCHARGED INCIDENTS
Inmate
Missing Cash
Trostle, Nicholas
$506.20
Diaz, Fabian
Shoemaker, Karen Elaine
$484.00
Bui, Hung Hguyet
$510.00
McLeod, Michael
$242.70
Markland, Charles Michael
$287.00
Markland, Charles Michael
-$107.00
Markland/Shoemaker
$359.00
Knuth, Charles Christian
$340.00
Beebe, Kim L.
$403.90
Triqueiro, Jonathan Paul
$512.00
Swan, Leon Jade
$400.00
Freeman, James Dean
$700.00
Panidis, Justin K.
$811.00
Jackson (Horton), Lawanda
$203.00
Mesa, Felix Callazo
$80.00
Sceeles, Steven R.
$209.00
King, Gary Ralph
$244.80
Hyden, Jonathan G.
$221.00
Extra Checks
$243.00
$263.20
$484.00
$500.00
$367.20 - $124.50
$287.00
$1,000.00 (5 M.O. not dep)
$359.00
$340.00
$403.90
$512.00
$1,147.52 - $747.52
$700.00
$836 - $25 (undeposited)
$203.00
$80.00
$209.00
$244.80
$221.00
Explain



Went through each transaction in the same order
With Same Questions
Hands on for jury
History of Drawer
=$1,680
Deposit Slip
Missing Cash
Missing Cash
$1,680
-1,241
$ 439
Unrecorded Item on Deposit Slip
Missing Cash
$1,680
-1,241
$ 439
Lather, Rinse, Repeat



39 times
By about the 5th or 6th time some jurors were
there before I was
Carnac
Result?





Guilty of all 20 counts (we dismissed two)
Sentenced in February Friday
Our recommendation: 22 months
Defense recommendation: 90 days
Sentence: 22 months
Tyrone Dash Trial
Master the Detail



Remember the spreadsheet of bank and credit
card records
That’s got to be accurate
Don’t give the defense a foothold
Simplify
Give the Jury Enough to Calculate
the Answer Themselves
if They Want To
But don’t force them to review the detail
First Key is Frame of Reference
Jury Can Always come back to




Timeline
Pictures of Property
Pictures of Key Checks
Pictures of Victims
TIMELINE
Year
Event
Jan 2000
Dash Initial Involvement
May 2000
$150,000 mortgage through Bank of America on Frances’ personal residence
Jul 2000
Dash Largely Assumes Control of Frances' Finances
Jul 2000
$300,000 Frontier Bank Construction Loan
Jan 2001
$170,000 Frontier Bank Construction Loan
Mar 2001
Church Removed from Control over Frances’ Assets
Jul 2001
Last of Frances' Salomon Smith Barney Investment Account Exhausted
Nov 2001
Cash Value of Frances' Jackson Nat'l Life Insurance Policy Spent
Jan 2002
Dash Obtains Power of Attorney for Frances
Mar 2002
323 Bellevue E. Apartment Sold for $500,000
Jun 2002
$217,500 World Savings Bank Loan on Personal Residence (refinance of
Bank of America mortgage)
Mar 2003
$200,000 loan on 310 Bellevue E. Apartment
Jul 2003
$297,500 Ameriquest Loan on Personal Residence (refinance of World
Savings Bank mortgage)
Oct 2003
310 Bellevue E. Apartment Sold for $800,000
Apr 2004
$324,000 Ameriquest Loan on Personal Residence (refinance of earlier
Ameriquest mortgage)
Apr 2005
Dash Removed from Control of Frances' Finances
Pictures of Property
Second Key is Summaries


Summaries of “selected” transactions
For example, not all withdrawals, just
withdrawals to defendant
Summaries of selective
transactions – just withdrawals to
the Defendant
Summarize all but highlight a few

Summarize all credit cards, but group by
categories and emphasize categories
Use in cross ex
 Use in closing
 Give jury the full doc but do their work for them

Summarize in Imaginative Ways


- ATM Withdrawals.xls
- ATM-Cash Advance Calendar.xls
Summarize in Striking Ways
Credit Card Charges for Dash's Benefit
Paid for by Frances Taylor Funds
140000
120000
100000
80000
60000
40000
20000
0
2000
2001
2002
2003
2004
2005
Think About Distributing to Jury
Sometime One Summary can Tell the
Whole Story
Frances Taylor Net Worth 1997-2005
$1,600,000
$1,400,000
$1,200,000
$1,000,000
$800,000
$600,000
$400,000
$200,000
$0
1997
1998
1999
2000
2001
2002
2003
2004
2005