STATE OF MARYLAND IN THE CIRCUIT COURT V. OF MARYLAND FOR CATHERINE E. PUGH ANNE ARUNDEL COUNTY CASE No.6??7f 2 [y'Ziyg CRIMINAL INFORMATION The Maryland State Prosecutor Charlton Howard, by and through Kelly B. Madigan, Deputy State Prosecutor, and Sarah R. David, Senior Assistant State Prosecutor, having considered the said case, and being duly authorized by law, now presents that at Anne Arundel County, pursuant to a common scheme and plan to conceal the nature and extent of her business, Healthy Holly LLC, CATHERINE E. PUGH committed the o?'enses speci?ed herein: . At all times pertinent, CATHERINE E. PUGH was a duly elected State Senator in the Maryland General Assembly, representing the 40?[1 District. . From on or around 2008 through and including 2015, PUGH served as a member of the Senate?s Finance Committee, a committee which considered issues related to health care facilities, public health, as well as, property, casualty, life and health insurance. . From on or around 2013 through and including 2016, PUGH served as the Chairwoman of the Senate's Health Subcommittee, the purpose of which was to study and consider issues related to health and to health insurance. . At all times pertinent, PUGH, as a Maryland State Senator, was required by the State Government Article ?l 5-602 to ?le a ?nancial disclosure statement with the Maryland State Ethics Commission, under oath or af?nnation, disclosing her ?nancial a?'airs for the prior calendar year, including: SCHEDULE - All interests in any corporation, partnership, limited liability partnership or limited liability company held during the reporting period, whether or not the entity did business with the State, and SCHEDULE - The name and address of any places of employment or business entities wholly or partially owned, ?'om which income was earned during the reporting period whether or not the entity did business with the State. . From on or about January 1997, PUGH became a sole or partial owner of a business entity registered in Maryland under the name Catherine E. Pugh and Company, Incorporated. . From on or about December 2001, PUGH became a sole or partial owner of a business entity registered in Maryland under the name P.C. LLC. From on or about January 2011, through and including the present, PUGH was a sole or partial owner of a business entity registered in Maryland under the name Healthy Holly LLC. . On or about September 5, 2012, PUGH opened a business checking account, account (redacted), held at The Harbor Bank of Maryland (?Harbor Bank?), in the name of Healthy Holly LLC. PUGH was the sole signer on the account and the ownership documents for the checking account contained personally identifying information, as well as, her signature. The stated purpose of Healthy Holly LLC as reflected on the bank account ownership records was FOR BOOKS- STORY BOOK FOR . Also on or about September 5, 2012, PUGH signed a Limited Liability Company Authorization Resolution for Healthy Holly LLC with Harbor Bank stating that 10. 11. 12. CATHERINE E. PUGH, certify that I am a Manager or Designated Member of the above named Limited Liability Company organized under the laws of Maryland, Federal Employer ID. Number 27-4742386 engaged in business under the trade name of HEALTHY HOLLY LLC, and that the resolutions on this document are a correct copy of the resolutions adapted at a meeting of all members of the Limited Liability Company or the person or persons designated by the members of the Limited Liability Company to manage the Limited Liability Company as provided in the articles of organization or an operating agreement, duly and properly called and held on 8-1-12 (date). These resolutions appear in the minutes of this meeting and have not been rescinded or modi?ed. From on or about October 2013, through and including April 2019, PUGH was a partial owner of a business entity registered in Maryland under the name 2 Chic Boutique. During calendar year 2012, Healthy Holly LLC earned at least $108,000 in income through the sales of self-published Healthy Holly children?s book series, including $100,000 iron} the University of Maryland Medical System, $7,500 ?'om the Maryland Automobile Insurance Fund and $500 from Riverside Health of Maryland, Inc. In her 2012 ?nancial disclosure statement ?led with the Maryland State Ethics Commission, under Schedule - Interests in Corporations and Partnerships, PUGH disclosed her interest in TIA Catherine E. Pugh Co., but failed to disclose the interest she held in Healthy Holly LLC. Under Schedule EmploymentlBusiness Ownership, PUGH again disclosed TIA Catherine E. Pugh Co., but failed to disclose Healthy Holly LLC. 13. I4. 15. 16. During calendar year 2013, Healthy Holly LLC earned at least $8,128 in income through the sales of self-published Healthy Holly children?s book series, including $4,448 from the Maryland Automobile Insurance Fund, which was passed through the Associated Black Charities. In her 2013 ?nancial disclosure statement ?led with the Maryland State Ethics Commission, under Schedule - Interests in Corporations and Partnerships, PUGH disclosed her interest in TIA Catherine E. Pugh Co., but failed to disclose the interest she held in Healthy Holly LLC or the interest she held in 2 Chic Boutique LLC. Under Schedule Employment/Business Ownership, PUGH again disclosed Catherine E. Pugh Co., but failed to disclose Healthy Holly LLC. During calendar year 2014, Healthy Holly LLC earned at least $6,500 in income through the sales of self-published Healthy Holly children?s book series, including $6,500 from CareFirst Blue Cross Blue Shield, which was passed through the Associated Black Charities. In her 2014 ?nancial disclosure statement ?led with the Maryland State Ethics Commission, under Schedule Interests in Corporations and Partnerships, PUGH disclosed her interest in TIA Catherine E. Pugh Co. and in 2 Chic Boutique LLC, but failed to disclose the interest she held in Healthy Holly LLC. Under Schedule - Employment/Business Ownership, PUGI-I again disclosed TIA Catherine E. Pugh Co., as well as, 2 Chic Boutique LLC, but failed to disclose Healthy Holly LLC. 17. 18. 19. 20. During calendar year 2015, Healthy Holly LLC earned at least $100,000 in income through the sales of self-published Healthy Holly children?s book series, including $100,000 from the University of Maryland Medical System. In her 2015 ?nancial disclosure statement ?led with the Maryland State Ethics Commission, under Schedule Interests in Corporations and Partnerships, PUGH disclosed her interest in TIA Catherine E. Pugh Co. and in 2 Chic Boutique LLC, but failed to disclose the interest she held in Healthy Holly LLC. Under Schedule Employment/Business Ownership, PUGH again disclosed TIA Catherine E. Pugh Co, as well as, 2 Chic Boutique LLC, but failed to disclose Healthy Holly LLC. During calendar year 2016, Healthy Holly LLC earned at least $345,000 in income through the sales of self-published Healthy Holly children?s book series, including $100,000 ?-om the University of Maryland Medical System and $50,000 from Kaiser Permanente. In her 2016 ?nancial disclosure statement ?led with the Maryland State Ethics Commission, under Schedule Interests in Corporations and Partnerships, PUGH disclosed her interest in TIA Catherine E. Pugh Co. and in 2 Chic Boutique LLC, but failed to disclose the interest she held in Healthy Holly LLC. Under Schedule Employment/Business Ownership, PUGH again disclosed TIA Catherine E. Pugh Co., as well as, 2 Chic Boutique LLC, but failed to disclose Healthy Holly LLC. COUNT I From on or about January 3, 2017 in Anne Arundel County, Maryland, Catherine E. PUGH did will?rlly and falsely make af?rmation as to material facts in a Financial Disclosure Statement Form 19 Legislators required by the State Government Article 15-602 to wit: did complete and submit the Financial Disclosure Form covering calendar year 2016, the contents of which were af?rmed by executing the following statement thereon and the Financial Disclosure Form could not have been submitted without af?rming the following af?rmation have read and I understand that by submission of this electronically ?led ?nancial disclosure statement, I hereby swear or af?rm that the information contained in it is complete and accurate to the best of my knowledge and belief?. PUGH well-knowing that the facts sworn to were materially false and incomplete in that: 3.. Under Schedule Interests in Corporations and Partnerships, PUGH falsely stated that during calendar year 2016 the only interest she held in any in any corporation, partnership, limited liability partnership 0r limited liability company corporation, whether or not the entity did business with the State, was in TIA Catherine E. Pugh Co, and in 2 Chic Boutique LLC, despite well-knowing that she was a sole or partial owner of Healthy Holly, and b. Under Schedule Employment/Business Ownership, PUGH falsely stated that during calendar year 2016, the only business entity, wholly or partially owned by her, from which income was earned was TIA Catherine E. Pugh Co, and 2 Chic Boutique LLC, despite well?knowing that Healthy Holly LLC, a business entity that she was a sole or partial owner of, earned income, in violation of ?9-101 of the Criminal Law Articie, Annotated Code of Maryland, and against the peace, government and dignity of the State. CR 9-101 Pexjury - 10 years CJIS Code 1-0307 By: CHARLTON T. HOWARD STATE. PROSECUTOR ju/U'W (1am Kelly B. digan ?g Of?ce of the State Prosec or Suite 410, Hampton Plaza 300 East Joppa Road Towson, Maryland 21286 (410) 321-4067 0 cc of the State Prosecutor Suite 410, Hampton Plaza 300 East Ioppa Road Towson, Maryland 21286 (410) 321-4067