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INFORMATION ‘STATE OF CONNECTICUT ‘Disposition dale JOCRTY Rev, 1-11 SUPERIOR COURT Pa Co Ta ‘genera TT UCF46.007 Office of the Chief State's Attorney - U.C.F. 8700 Title, Allegation and Counts Sano Coe ae aT Tana TH ATE Sina SKYERS, Angela Oxford ae BET undersigned Prosecutn 1 Crozier Court, Oxford, CT 06478 o2a71968 | Kithority of ine Superior Court oR ToT Gapemea__—[Cauase | Ofthe State of Connecticut New Brita Me 18 charges that: ‘at One = OS GT Pees canraedto— Pave Ramon Larceny First Degree by Defrauding a Public Community To Orr aio sy TT oC SS TAT Wethersfield August 27, 2012 - Oct. 23,2012 | 53a-122(a)(4) RTT ET Fee Unemployment Compensation Fraud Foo ror aot inven of or Sas br Wethersfield August 27, 2012 - Oct. 23,2012 |31-273(f)(2) Sara he oo TT 5a TTBS inv of er Sle aber Oa Sang ae AREA, See other sheet for adiional counts Ff ; 7 : X24 Qo © Ehauany db db dha Le \ eb, Court Action ‘Ga oh eee do BST ee ay (Cex pan aay {oto ose) [Diese] Ger Quy (Liateney Cea wr astgs Sean pe no er eaint Pea date an Remit ‘Adatontcaposton s I 1 s I ‘ 2 Is I 3 Date ‘Other CaurAation Tae ReaRTRIARaE [oa ana [im Conc [Efacnatatoes Ci] Foretuevaes Forte eels aden eae ea Sb e-em Teideane ‘a Care [roe rma eed Prana oral dopoeion [Renoisimantaron oral eeponion Sores (Om) This 5 page 1 of @ 2 page infarmation [Sree nape) INFORMATION ‘STATE OF CONNECTICUT isp ale ABORT! Rov 1-4 SUPERIOR COURT Pole Case ner aay rae “agsy nar uCF16-007 Office of the Chief State's Attorney -U.C.F. 8700 Arrest Warrant se" 4g [State of Connecticutvs. SKYERS, Angela To: Any Proper Oficer ofthe State of Connecticut By Authority ofthe State of Connecticut, you are hereby commanded to arest the body of the within-named accused. ("X" ail that apply) [1 A. Accused is ordered to be brought before a clerk or assistant clerk of the Superior Court. 1B. Accused is not entitled to bail ITA, B or both are checked above, you shall without undue delay bring the arrested person before the clerk or assistant clerk of the Superior Court for the geographical area where the offense is alleged to have been, Comrmited, orif the clerk's ofice is not open, to a cemmuntty correctional center within said geographical area, or the nearest community correctional cenierifm0 such center exists in the geographical area, or to the Correctional Institution, as the case may be. Dries tomas esate prosecitor O C.Bail set at 1 D. Non-financial conditions of release: 2 E. Conditions of release not deter By the Court [ne a ie Spore Cond Date eaeetiti Return On Arrest Warrant or “own at me = | ‘State of Connecticut Then and there, by virtue ofthe within and foregoing complaint and warrant, 'arrested the body ofthe wilhin-named accused and read the same in the heaving of said accused; and have said accused here in court for examination, ‘nest (Oces signature and Depaenenty Date. (Other Court action Judge ‘This is page 2 of a 2 page Information ARREST WARRANT APPLICATION an BER BAD Rev. t4 ‘STATE OF CONNECTICUT ‘Suppor Anas sean See saa SUPERIOR COURT Ces Ty no aera sor a UCF16-007 Office of the Chief State's Attorney - U.C.F. 5700 eT am Se ama SKYERS, Angela Oxford New Britain: xearumaer 15, 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 set forth inthe: [X] Affidavit Below. — L] Affidavit(s) Attached, 5 aie eT ebaute we Wawa Obl lates ay WAR MES Affidavit J! ‘The undersigned affiant, being duly sworn, deposes and says: 1. That the undersigned affiant, Peter J. Corcoran, being duly sworn, does depose and state that | am an Inspector with the Division of Criminal Justice, Office of the Chief State's Attorney, having more than 23 years of experience in the field of law enforcement and criminal investigations. At all times mentioned herein, Iwas acting in my official capacity as a member of the aforementioned agency. The following facts and circumstances are related from personal knowledge and/or observations and include information related to this affiant by fellow officers and credible persons with knowledge of the facts and/or circumstances contained herein. 2. That on or about February 1, 2076, the Unemployment Compensation Fraud Unit of the Chief State's Attorney's Office opened an investigation into a complaint received from the Connecticut Department of Labor (DOL), Benefit Payment Control Unit (BPC), that an individual identified as Angela Skyers of 1 Crozier Court, Oxford, Connecticut, had defrauded the DOL of approximately $8,033.00 in unemployment compensation benefits. Two DOL audits revealed that Ms. Skyers failed to report her wages while employed at Quinnipiac University (Quinnipiac) for the weeks ending July 7, 2012, through October 6, 2012, and at Goodwin College (Goodwin) for the weeks ending October 13 through October 20, 2012. The DOL is responsible for administering unemployment compensation benefits in the State of Connecticut. Unemployment benefits have been designated as economic support for individuals who have become unemployed through no fault af their own. 3, Every person who initiates a claim for unemployment compensation benefits in the State of Connecticut receives a Benefit Rights Information (BRI) booklet explaining the procedure. In that publication, claimants are warned that there are severe penalties for submitting false statements or withholding information about employment and earnings in order to receive or increase benefits. Claimants are instructed to read the BRI booklet. The claimants are advised that they must report all work, including self-employment, when the work is performed, even if no payment is received at the time. Claimants are warned that violators are subject to criminal prosecution and, if found guilty, are (Tis is page #of a6 nego Atidavt) a) Fob ob berg ia Diete Lance a OnE OT swat a sa Roa BRS sunt eae don er Finding ‘The foregoing Application for an arrest warrant, and affidavit(s) attached to said Application, having been submitted to and considered by the undersigned. the undersigned finds from said affdavi(s) that there is probable cause to belleve tat 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 | Sin60 at (IY or fowry On Dato) ‘ied acne ode Tia eter) Tome of igeudge Tal Referee Signature ARREST WARRANT APPLICATION WDCR Sea v.41 STATE OF CONNECTICUT Bea sean ‘SUPERIOR COURT fr be See 26,202,903 lee mieeal Tan (at Fe way Reidoncn Teor 06ND) Comm OR TRON TOWT | ceogapncar SKYERS, Angola Oxford New Britain —ieanenter 1 Affidavit - Continued subject to incarceration andJcr a fine. The following is written on the cover of the BRI booklet: "You are responsible for understanding the information in this booklet. Please read the information carefully to leam procedures for filing claims, eligibility requirements for benefits and the appeals process." 4. In order for a claimant to receive ongoing unemployment benefits in the State of Connecticut, they must call into an automated reporting system (TeleBenefits Line) on a weekiy basis. In order to access an unemployment benefits account the claimant is required to enter his or her social security number followed by a personal identification number (PIN) that the claimant created. During this automated call-in session the claimant is required to answer a series of at least seven questions that have been designated to determine the ongoing eligibilty of the claim. The questions are answered on the phone pad by responding “yes/no” to each inquiry. For instance, one of the first questions asked is if the individual is able, available, and actively seeking full-time employment. Another question asks if the claimant worked full-time, part-time, or was self-employed during the specific claim week. The claimant's answers are recorded by the computer. ifthete are any problems during the callin sessions, the claimant is directed to speak to a claims representative during regular business hours. This process must take place before the weekly benefits are released to the claimant. (NOTE: The DOL switched from issuing checks to issuing a debit card or direct deposit on the first week of February 2011. Therefore, the last check a claimant would have received would have been for the week ending January 29, 2011, and the first week of electronic payment would have been for the week ‘ending February 5, 2011.) §. That according to DOL records, in addition to filing the unemployment compensation claims referred to in paragraph 2, Ms. Skyers had previously received 11 weeks of benefits for the weeks ending August 16 through October 25, 2003. 6. That according to DOL documents, on or about August 6, 2012, Ms. Skyers applied and was approved for unemployment compensation benefits. Under this claim Ms. Skyers received 16 weeks of benefits back to the Claim Week Ending (CWE) July 7 and through CWE October 20, 2012. On February 1, 2016, | contacted Mr. Marco Crachat, DOL, BPCU, as to why Ms. Skyers received benefits prior to her applying for benefits on August 6, 2012. On February 2, 2016, Mr. Crachat emailed me "The weeks 7/7/12 through 8/25/2012 were entered after she opened her claim. She requested a back date hearing to back date her claim to 7/1/2012 which represented the first week after her separation from Housantonie [sic] Community Tech [sic]. She was approved on the back date of the claim on 8/27/2012 and would have been asked the 7 questions prior to having the claims approved by the adjudicator. The claims were entered manually in the claims exam department based on the approval from the adjudicator." (Note: The "7 questions" Mr. Crachat referred to are the questions outlined in paragraph 4. Additionally, in a subsequent email to me, Mr. Crachat confirmed that Ms. Skyers was separated from Quinnipiac, not Housatonic Community College] (This ig page 2 of @ 6 pago AMhsout) oe STI, 7 Feb eo Aub Tae OL. ben SET a ah be iH WRT ed agate Caps Tart Cot Rey PREY surat hd. ib, dU CL AK Reviewed (Ine Inge Taal tera) —~ al ARREST WARRANT APPLICATION BD.CRBAa Rev. 1-48 STATE OF CONNECTICUT Gos.gstz— ‘SUPERIOR COURT Pre Bee 304, 982,905 peer Tia (eas Pes Mie a Tees (om) of acaiad | COaTEEETEBATION | cecgarncal SKYERS, Angela Oxford New Britain Roaramter 1 Affidavit - Continued 7. That the DOL mailed Certification of Earnings documents to: = Quinnipiac to ascertain Ms, Skyers' weekly wages and hours worked for the period from July 1 to October 20, 2012. According to the completed wage information, during the CWE July 7, 2012, Ms. Skyers received $5,302 for vacation pay: for the CWEs July 14 through August 25, 2012, she received $528.12 in gross weekly wages; and for the CWEs September 1 through October 6, 2012, she received $955.00 in gross weekly wages = Goodwin to ascertain Ms. Skyers' weekly wages and hours worked for the period from September 23, to November 3, 2012. According fo the completed Certification of Eamings, Ms. Skyers was hired on October 1, 2012, and was still employed when the document was completed on November 5, 2012. According to the completed Certification of Earnings, Ms. Skyers worked 80 hours and received $2,884.64 in gross wages for both CWE October 20, 2012, and CWE November 3, 2012. [Note: For audit purposes, DOL recalculated the gross wages and hours worked for CWE October 13, 2012, and October 20, 2012. DOL assigned 40 "total hours worked this week" and $1,442.32 in “gross wages earned this week" to each of the two CWEs,] 8. That according to the DOL audit, between September 5 and October 23, 2012, Ms. Skyers accessed the DOL Telebenefits Line 8 times. During each of the calls, Ms. Skyers answered "yes" to the question of being able and available for full-ime employment and answered “no” to the question have you worked full-time, parttime, or were you self-employed during that particular benefit week. According to DOL, Ms. Skyers failed to report the weekly wages she received for 8 weeks during the above time period while working for either Quinnipiac or Goodwin. Additionally, as referenced in paragraph 6, Ms. Skyers received 8 weeks of "back-dated” benefits for CWE July 7 to CWE August 31, 2012. According to the DOL audit, as a result of Ms. Skyers failing to report her wages, she received approximately $8,033.00 in unemployment benefits to which she was not entitled. 9. That on or about January 7, 2013, the DOL malled an "OVERPAYMENT AND PENALTY WEEK(S) HEARING REQUEST" letter to Ms. Skyers. The ietter informed her that "On the basis of available evidence, this Agency has made a preliminary determination that your unemployment compensation account is overpaid $1,236.00 with administrative penalty because: You failed to properly report your earnings from Goodwin College INC for the week(s) ending October 13, 2012 through October 20, 2012. You have a right to a hearing to be conducted by an Unemployment Compensation examiner to address whether you were overpaid benefits as stated above, and if you were overpaid, whether such overpaid benefits were received because you knowingly failed to disclose a material fact in order to obtain benefits." According to DOL records, Ms. Skyers did not respond to the notification. 10. That on or about March 27, 2013, the DOL mailed an “Overpayment and Administrative Penalty Decision" letter to Ms. Skyers that informed her that "Based on a review of the case file and: Your [sic] (This is page 2 of 6 page Affidavit) oe TT Feb. 2G ange SEO fauna cea iilstticmera oie a gr ST Rm BT oy Tt ap Ro = Wisin.) 3 Mebusn Boal a ARREST WARRANT APPLICATION STATE OF CONNECTICUT CGS 4528 SUPERIOR COURT be bos se, s02, 383 pene Tae Gaal Fad We aD esis (ow) ofacanad | Cate STSSSTOA [acca SKVERS, Angola Oxford Now Britain |avarumoer_ 1 Affidavit - Continued feilure to request or attend a hearing a determination has been made that your unemployment compensation account is overpaid $1,236.00 and you have been assessed administrative penalty weeks because You [sic] failed to properly report your eamings from Goodwin College INC for the week(s) ending October 13, 2012 through October 20, 2012. The evidence supports a finding that you knowingly made a false statement or representation or knowingly failed to disclose a material fact in order to obtain or increase benefits." 11. That on or about July 29, 2014, the DOL mailed a "PREDETERMINATION HEARING REQUEST REGARDING OVERPAYMENT AND MONETARY PENALTY’ letter to Ms. Skyers, The letter informed Ms. Skyers that "Based on the information available, the Labor Department has made an initial decision that you were overpaid a total of $13,594.00 which includes monetary penalties for each Benefit Year Ending (BYE) date listed below: For the BYE 7/6/2013, you were overpaid $6,797.00 in unemployment benefits, which results in a monetary penalty of $6,797.00. This is because you did not let the Department know about your total earned wages from Quinnipiac University for weeks ending July 7, 2012 through October 6, 2012. You have the right to a hearing on the overpayments listed above. if you received benefits that you were not supposed to, we will also decide whether you received the benefits because you intentionally did not tell us important information or you told us something that you knew was false to receive the benefits.” According to DOL records, Ms. Skyers did not respond to the notification. 12. That according to DOL records, monthly billing statements have been sent to Ms. Skyers regarding her overpayment since April 2013. According to DOL records, Ms. Skyers made a $1,000.00 payment on July 18, 2013, but no other payments have been made since. 13, That on February 9, 2016, Inspector Mark Puglielli (Division of Criminal Justice, Office of the Chief State's Attorney) and | attempted to interview Ms. Skyers at her residence. Since no one was home at the time, | left my business card for Ms. Skyers to contact me. 14, That on February 10, 2016, | received a phone call from Attorney Eroll Skyers, who identified himself as Ms. Skyers' husband. Attorney Skyers and | agreed to a meeting with Ms. Skyers at the United States Postal Service Office of Inspector General (USPS OIG), 50 Brewery Street, New Haven, CT, on February 22, 2016, 15. That on February 22, 2016, inspector Puglielli and | met Ms. Skyers and Attorney Skyers, at the office of the USPS OIG. Inspector Puglielli and | identified ourselves and | informed Ms. Skyers that we wanted to discuss with her the money she owes the DOL pertaining to her unemployment {This is page 4 of 26 page Affidavit) ate Seed AT 6 rig. Se Gis “po Sia enn ta oT Seg pt omg 3S ta 1 PT 26 mh [ pana Pema OMT) Ta avon gigs Wt eee) Bae ia i: ey sw S26] tb ARREST WARRANT APPLICATION BD.CR Eta Rew. 44 STATE OF CONNECTICUT cos. get28 ‘SUPERIOR COURT Pr Bie Ser 3P-, 282, 96-8 ‘werk. ud.2.90v atta ael Fra Wade ap Rasseree (To) ofacoesed Couto Be TARAITOWT | Sccrapicat SKYERS, Angela Oxford New Britain | araanmoer 15 Affidavit - Continued compensation benefits. | informed the Skyers that DOL conducted an audit of Ms. Skyers' account and discovered that she failed to report her wages while she was working at Goodwin and Quinnipiac, and simultaneously receiving unemployment compensation benefits. | explained that her case was referred to this office by DOL, and according to their records she had received approximately $8,033.00 in unemployment benefits as a result of her fraudulently failing to report her wages. | showed Ms. Skyers copies of the following documents: = Certification of Earnings from Quinnipiac for the period July 1, 2012, to October 20, 2012, which documented her weekly gross wages. = Certification of Eamings from Goodwin for the period September 23, 2012, to November 3, 2012, which documented her weekly gross wages. ~ Copies of the DOL Telebenefits Line voice responses which captured her answers to the DOL recorded questions when she filed for her weekly claims during the time-trame listed above. - Copies of the DOL Audit Screen Report. Ms, Skyers and Attorney Skyers stated that the audit was wrong and that Ms. Skyers' last day of work at Quinnipiac was on June 30, 2012. Ms. Skyers stated she did receive a chack from Quinnipiac in July 2012 for her vacation and sick leave pay, but she did not work at Quinnipiac during July 2012 and most of August 2012. Ms. Skyers stated she was hired by Quinnipiac in tate August 2012 as an Adjunct Professor and taught at least one course during the Fall 2012 semester. Ms. Skyers acknowledged that she did not report to DOL any wages, or the money she received for her vacation pay, from Quinnipiac. Ms. Skyers suggested that | contact Ms, Carol Lawlor, Director of Payroll and Compensation for Quinnipiac, to confirm that the Certification of Eamings submitted by Quinnipiac was incorrect. | fold Ms. Skyers that ! would contact Ms. Lawlor. Ms. Skyers stated she was hired as a full-time professor at Goodwin on October 2, 2012. Again, she acknowledged she did not report her wages to DOL while working at Goodwin during October 2012. Attorney Skyers asked if it was possible to pay DOL the money that Ms. Skyers owed. Inspector Puglielli and | explained to them the various payment options. 16. That on February 25, 2016, | received the following email response from Ms. Lawlor regarding the Certification of Earnings referenced above: "Hi Peter, {reviewed the attached. Allis in order except we missed one weekly amount by not posting the $528.12 in the 7/1/12-7/7/12 week - there should have been 8 weeks of payments for Angela's summer teaching. We also did not include a $250 stipend Angela was paid on 8/31/12 for a 2 day summer workshop she taught. Therefore, ihe total amount that should have been reported is $17,416.96 - not $16,638.84 a difference of $778.12. Please let me know if | should submit a correcting Certification of Earnings report. Thanks, (is is page 5 ofa 6 page Afisavit) Date ‘Sign any Fa kaye apt ga a ar aT cited ienks Spc Cal ay me ehh 46 2010 | 63.0 fe Me i geTige Tal Rate} ae a + =

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