KAMALA D. Hamas . Attomey General of California 2 1 LoU1s Vasquez . mum - 3 Attorney 1 Deputy Attorney General - 4 State Bar No. 21% 5090 - AUG 2 8 2812 2550 'posa com CA 93721 Telephone: (559) 477-1674 By; 6 Fax: (559) 445-5106 . . - 2 E-mail: Leanne.LeMon@doj.ea.gov - . 7 Attorneys for People 8 1 . 1 SUPERIOR COURT OF THE STATE OF CALIFORNIA 9 COUNTY OF TULARE - PEOPLE or THE STATE OF Court Case N0.: CALIFORNIACOMPLAINT - JEFF BRADLEY (DOB: 01/14/1974), . A SCOTT GARDNER (DOB: 09/25/1972Defendants. 20 - . 1 The undersigned is informed and believes that: - 21 . commabout and between January 1, 2008 through December 31, 2008, in the County of 1 Tulare, the crime of EMBEZZLEMENT OF PUBLIC FUNDS, in violation of Penal Code section . 24 . . 1 504, a felony, was committed by JEFF BRADLEY and SCOTT GARDNER, while said 1 defendants were officers of the Omce of Protective Services, Department of Developmental 26 7 Services, did unlawfully and fraudulently appropriate to a use or purpose not lawful execution ofhis trust, property which he had in his possession or imder his control Complaint (Tulare County) ng . 1 virtue of his trust and/or did unlawfully secrete said property with a fraudulent intent to F2 appropriate it to such a use and purpose contrary to Penal Code section 487, subdivision and 3 property being of a value exceeding nine hundred and fifty dollars 4 - It is further alleged that the said embezzlement and defalcation was ofthe public funds of - I 5 1 the Department of Developmental Services within the meaning of Penal Code section 514. 6 I COUNT 2 7 On or about and between January 1, 2008 through December 31, 2008, in the County of 8 Tulare, the crime of GRAND THEFT, in violation of Penal Code section 487, subdivision . 9 a felony, was committed by JEFF BRADLEY and SCOTT GARDNER, who did, during a 12 10 month consecutive period, and- while an agent, servant, or employee of the Department _of ll 1 Developmental unlawfully take from the Department of Developmental Services money . 12 orpersonal property of a value exceeding nine hundred and Efty dollars - 13 I COUNT 3 I .14 On or about and between January 1, 2008 through December 31, 2008, in the County is I of Tulare, the crime of PRESENTATION OF A CLAIM, in violation of Penal 16 Code section 72, a felony, was committed by JEFF BRADLEY and SCOTT GARDNER, who 17 did and with intent defraud, present for allowance or payment a false or Eaudulent 18 claim, bill, account, voucher about and between January 1, 2008 through December 31, 2008, in the County of 21 Tulare, the crime of PUBLIC OFFICER CRIME, in violation of Penal Code section 424, 1 22 subdivision `a felony, was committed by JEFF BRADLEY, who being a person described I 23 in Penal Code section 424 charged with the receipt, safekeeping, transfer, or disbursement of it 24 public moneys, did in a manner not incidental and minimal, without authority of law, appropriate I 25 the same, or a portion thereoi,'to personal use or the use of another. 26 COUNT 5 i 27 On or about and between January 1, 2008 through December 31, 2008, in the County of 28 Tulare, the crime-of PUBLIC OFFICER CRIME, in violation of Penal Code section 424, . 1 2 I . Complaint (Tulare County) i . 1 A 1 subdivision a fe1ony,.was committed by JEFF BRADLEY, who being a person described 2 in Penal Code section 424 charged with the receipt, safekeeping, transfer, or disbursement of i I 3 public moneys, did in a manner not incidental and minimal, knowingly keep a false account, or 4 `make a false entry or erasure in an account of and relatinglto the same, to wit, by directing and 5 authorizing false entries on overtime slips submitted by Scott Gardner respect to the number 6 of hours worked and the reasons the hours were worked. 7 COUNT 6 I 8 I On. or about and between January 1, 2008 through December 31, 2008, in the County of 9 Tulare, the crime of PUBLIC OFFICER CRIME, in violation of Penal Code section 424, 10 subdivision a felony, was committed by JEFF BRADLEY, who being a person described 1 in Penal Code section 424 charged with the receipt, safekeeping, transfer, or disbursement of - I I 12 public moneys, did in a manner not incidental and minimal,-iiaudulently alter, falsify, conceal, 13 destroy and/or obliterate such account, Ito witi by directing and authorizing false entries on 14 overtime slips submitted by Scott Gardner with respect to the number of hours worked and the . 15 reasons the hours were worked. . . 16 It is further alleged that prosecution of JEFF BRADLEY and SCOTT GARDNERsame conduct alleged in this complaint, was pending in Tulare Superior Court from February 18 8, 2010 February 7, 2011, in case number VCF232939 and that the statute oflimitancns 19 1 is tolled and extended for that period, within the -meaning of Penal Code section 803, subdivision declare upon information and belief and under penalty of perjurythat the foregoing is true 22 and correct and the Complaint consists of 6 counts. 23 Executed in Fresno, California, the 22nd day of August, 2012. I I 24 1 - Leanne Le Men -- a 26 Deputy Attomey General . 28 . - I - cempieam (Tulare county) I . - 1 I Agency: Pomcrvillc Police Department (case 08-6497) I I . 2 count sa; 261:; 1-mx mx ms um. mm 3 JEFF BRADLEY 5'7" 185 BLU BLD . i SOOTT GARDNER 6'1=112011so24s7 95065015.doc . - Complaint (Tulare County) . I .