District Court, Douglas County, Colorado

Douglas Combined Courts

4000 Justice Way DATE FILED:
DATEOctober
FILED:18,October
2019 8:53
18, AM
2019
Castle Rock , CO 80109
COURT USE ONLY
THE PEOPLE OF THE STATE OF O
Case No:
COLORADO
vs. GJ Case No.: 19 CR 1
KELLY RENEE TURNER ,
Defendant Ctrm: 201

18TH JUDICIAL DISTRICT GRAND JURY INDICTMENT

COUNT 1: MURDER IN THE FIRST DEGREE, C.R.S. 18-3-102( l )(f ) (FI )

COUNT 2: MURDER IN THE FIRST DEGREE, C.R .S. 18-3-102( l )(a) (FI )

COUNT 3: CHILD ABUSE, C.R.S. 18-6-401 (1),(7)(b)( I) (M2)

COUNT 4: THEFT, C.R .S. 18-4-401(1 ),(2)(i) (F3)

COUNT 5: THEFT, C. R .S. 18-4-401( l ),(2)(h) (F4)

COUNT 6: THEFT, C. R .S. 18-4-401(1),(2)(g) (F5)

COUNT 7: CHARITABLE FRAUD, C.R .S. 6-16-11 l ( l )(g) (F5)

COUNT 8: CHARITABLE FRAUD, C. R .S. 6-16-1 ll ( l )(g) (F5)

COUNT 9: CHARITABLE FRAUD, C.R.S. 6-16-11 l ( l )(g) (F5)

COUNT 10: ATTEMPT TO INFLUENCE A PUBLIC SERVANT, C.R .S. 18-8-306

(F4)

COUNT 11: ATTEMPT TO INFLUENCE A PUBLIC SERVANT, C.R .S. 18-8-306

(F4)

COUNT 12 : SECOND DEGREE FORGERY, C.R.S. 18-5- 104 (Ml )

COUNT 13 : SECOND DEGREE FORGERY, C.R.S. 18-5- 104 (Ml )

1
 District Court, Douglas County, Colorado
Douglas Combined Courts COURT USE ONLY
4000 Justice Way
Castle Rock, CO 80109

THE PEOPLE OF THE STATE OF Case No:

COLORADO
vs. GJ Case No.: 17 CR 1
KELLY RENEE TURNER ,
Defendant Ctrm: 201

18TH JUDICIAL DISTRICT GRAND JURY INDICTMENT

,
Of the 2019 term of the 18th Judicial District Grand Jury; the 2019 18 h Judicial District
Grand Jurors, chosen, selected and sworn in the name and by the authority of the People of the
State of Colorado, upon their oaths, present the following indictment and described acts, all
committed within the County of Douglas, State of Colorado, all done contrary to the form of
statutes in such case made and provided , and against the peace and dignity of the People of the
State of Colorado, as stated in the counts attached hereto:

COUNT 1-MURDER IN THE FIRST DEGREE (FI )

Between and including June 21 , 2010 and August 20, 2017, Kelly Renee Turner
unlawfully, feloniously, and knowingly caused the death of , a child who had
not yet attained twelve years of age, and the defendant was in a position of trust with
--
respect to the victim; in violation of section 18 3 102( 1 )(f ), C.R.S.

COUNT 2-MURDER IN THE FIRST DEGREE ( FI )

Between and including June 21, 2010 and August 20, 2017, Kelly Renee Turner
unlawfully, feloniously, after deliberation, and with the intent to cause the death of a
person other than herself, caused the death of --
; in violation of section 18 3
102( I )(a), C.R .S.

COUNT 3-CHILD ABUSE (M2)

Between and including May 13, 2008 and October 9, 2018, Kelly Renee Turner
unlawfully, knowingly, or recklessly, permitted , a child, to be unreasonably placed in
a situation which posed a threat of injury to the life or health of the child ; in violation of
--
section 18 6 401( 1 ),(7)(b)( I ), C.R.S.

2
The offenses enumerated in in Counts 1, 2, and 3 were committed in the following
manner:

On 10/09/2018, Det. Melissa Williamson was asked to assist the Jefferson County
Sheriffs Office with a child abuse investigation. Kelly Turner, also known as Kelly Gant
(DOB 06/ 24/1978), and her daughters, and HT (DOB
02/19/2000). In July, 2018, Turner moved from unincorporated Jefferson County,
Colorado, to 10303 Cherryhurst Lane, Highlands Ranch, Colorado, in unincorporated
Douglas County. The investigation was initiated by Children’s Hospital , Colorado,
(CHCO) doctors in concert with the Jefferson County Department of Human Services.
The initial Human Services referral indicated the following, in part:
Intrafamilial information: Also noted in the case was Dr. Antonia Chiesa with Children 's
Hospital. Reporters are concerned for medical child abuse, which involves . has
been seen at Children ’s the last few years. Her last Primary Care doctor just retired and
she has started with a new one. She started being seen here in 2013 after moving from
Texas. It was not until 2016 that MOC [mother of child] informed doctors that had
cancer in Texas from the ages of 2-5 and was treated with chemo and radiation. The new
primary care doctor became suspicious about this and confirmed with hospitals and
doctors in Texas that she never had cancer and never had treatment. This raised a red
flag for the reporting parties.
MOC is now bringing child in for several appointments for bone pain. Reporting parties
did more research and found articles, blogs, Facebook pages and news stories where
MOC describes several medical conditions that has not based on her medical
records. ’s younger sister died in 2017 at the age of 7. Now that this has come
up with there are concerns about ’s death and care as well. presented at
Children s Hospital originally in 2013 with developmental delays and was eventually
'
diagnosed with Autism . She then started being seen for constipation, this eventually got
much worse. Her medical condition got worse over time and she ended up dying if
intestinal failure. This was somewhat controversial with different doctors. When
started getting sick, MOC reported severe pain related to eating. Eventually was
put on a feeding tube and then IV nutrition. MOC was told that she would not be able to
sustain on IV nutrition and was given the option to take home on hospice. She died
a few weeks later. Prior to her death, was featured on several news stories both
locally and nationally. There is a concern that MOC may have been benefitting from this
attention and motivated some of the medical treatment MOC sought for both and
. There is a concern that MOC has lied about the children ’s medical conditions and
therefore may have caused harm to the children and or caused them to have significant
medical procedures. There is also concern that MOC has a financial and social
motivation for her children’s medical conditions, both real and fictitious. MOC lives with
, her 18-year-old daughter and her parents. It has been reported that FOC still lives in
Texas. It is unclear his involvement with the children.
MOC lives with MGPOC [maternal grandparents of child]
***Neither child has ever had cancer

has not had any surgeries other than ear tubes.

3
MOC reported several conditions and procedures that never happened.
MOC falsified info about undergoing treatment for Lymphoma. Entered system in
2013. came with a history of an infection of the mastoid bone. She has had confirmed
ear infections and athletic injuries.
2016-MOC started reporting had Lymphoma. MOC is reporting overwhelming bone
pain and has been in the clinic.
entered system at 2yo. Moved from TX. Developmental delay (Autism). A lot of
visits for constipation. Had ostomy to empty intestines. Her condition declined. Feeding
intolerance , seizures. Feeding was main reason for hospitalizations. Diagnosis of
intestinal failure. She had to have a tube from her intestine to stomach for food. Placed in
-
IV nutrition unsustainable. Hospice in 2017. Passed away.

On 10/ 11 /2018, Det. Randy Allen met with Douglas County DHS Intake Caseworker
Camille Gadziala, Sgt . Bost and Investigator Jones at Columbine Hills Elementary
(CHE). They met with Forensic Interviewer, Karla Hallacy, with Ralston House at CHE
at around 1 :00 pm. A forensic interview of was conducted in a conference room near
the main office inside the school.
described believing that she had previously had cancer, of an unknown type, and
being told that she had cancer by Turner. additionally detailed the death of her sister
, after protracted illnesses.

Investigators found no medical records to substantiate that ever had cancer of any
type.

-
Subsequent to that interview, Detective Allen conducted a recorded non custodial
interview with Kelly Turner, (a/k/a Turner Gant). Turner discussed her children, and
their various medical conditions. Turner specifically denied ever fabricating medical
conditions for her children.
Turner was asked about the fundraisers and the GoFundMe account that was created for
’s medical expenses. She said the GoFundMe account was set up to offset the costs
of ’s medications that Medicaid wouldn’t cover. Turner said took several
medications that were trial medications and were not certified by the FDA. also
took medications not suitable for anyone under the age of eighteen . Turner said
was insured by Medicaid because Jeffs insurance wouldn’t allow him to cover
because “she had a pre-existing condition.” is currently insured by Medicaid .
was treated at National Jewish for eczema and allergies. Turner said the doctors at
National Jewish “ ran a bunch of allergy tests” on . She said the test results came
back that had “some severe allergies.” Turner said, “ was autistic, so they
never really knew if she just didn’t like the color of something or if she really was
allergic to it.” She said was allergic to peanuts, tree nuts, chocolate, protein in
some milks, cats, and a certain pollen. Turner said also had several food aversions.
Turner said ’s intestines did not work and in November 2014, received an
ostomy. The doctors performed a procedure called a “belly ostomy.” Turner explained

4
that a “belly ostomy” is when the doctors pull a part of the small intestine out of the body
and attach it to a bag for waste disposal.
Turner said throughout ’s medical care, she had a Gastro-Jejunal (GJ ) feeding tube
and a Total Parenteral Nutrition (TPN ) line. Turner said in April 2017, was
-
discharged from the hospital on in home hospice care. Turner said in May 2017,
had a surgical procedure called a “ Mitrofanoff ’, which was done because ’s
bladder was no longer functioning properly. Turner said was seven years old and
still wearing diapers. She said had no idea how to go to the bathroom . When
was at home, nurses and doctors would visit and check her lines for
infections. Turner said ’s line got infected approximately six or seven times. Turner
said two of the line infections were staphylococcus and pseudomonas. She said
was admitted to Children’s Hospital in July 2017. Turner said Dr. Graham, who was a
hospice doctor, and gastroenterologist Dr. Jason Sodden both agreed that was only
receiving 30% nutrition. Turner said Dr. Sodden signed off on ’s hospice
admission paperwork . Turner said she signed a DNR [do not resuscitate directive] and
was transferred to the Denver Hospice facility on 08/02 /2017. Turner said
passed away on 08/ 20/2017 at Denver Hospice.

-
Turner talked about Munchausen by- Proxy syndrome and said she knows it means when
a parent or caretaker makes their child sick on purpose, or does things related to their
child’s illness for attention. Turner said the attention is on their child when, really, the
parent or caretaker is wanting the attention for themselves. Turner said, “That has never
been my case, like at all , whatsoever. You can talk to anyone that stood by my side
through and all of this.” Turner brought up “Munchausen-by-Proxy”
spontaneously as it was never introduced by Detective Allen or DHS. Turner said if she
,
had anything to “hide” she wouldn’t be talking or signing medical record release forms.
Turner eventually admitted fabricating ’s childhood cancer diagnosis, but maintained
that ’s medical conditions were completely legitimate.
Caseworker Gadziala described the separation test , [which is to separate from Turner
to see if is really having medical issues or not] to Turner and explained that Turner
was not allowed to be in the house with during the test. has not had any
additional medical problems or complaints of pain since 10/11/ 2018.
On 11/28/2018, ’s remains were exhumed and a complete autopsy was completed
by Pathologist Dr. Kelly Lear, who is also the Arapahoe County Coroner. Dr. Lear’s
report is a comprehensive 14-page report and in the summary stated the following:
" Based on ( he lack of anatomic findings to account for her chronic intestinal
failure , nonspecific toxicology results, and the inability to exclude caregiver-
fabricated illness, the manner of death is best certified as undetermined. ”
Dr. Lear also noted a lack of any anatomical findings which would account for ’s
stated cause of death, (intestinal failure) and a lack of anatomical findings to support
many of the conditions Turner claimed suffered from.
On 02 /21 /2019, Detective Seaman and Detective Williamson conducted an interview
with Dr. Jason Sodden at Children’s Hospital . Dr. Sodden stated he is a TPN specialist
and managed ’s TPN when she received it. Dr. Sodden became ’s primary GI
5
doctor in January 2017 and Dr. Robert Kramer was ’s primary GI prior. Dr. Sodden
remembered Turner told him that was “rejecting” her TPN, and he clarified that
does not happen. Dr. Sodden and other medical staff members had discussions with
Turner, about reducing ’s dependency on TPN . Turner refused, stating, “We’ve
already tried that.” Dr. Sodden had discussions with Turner regarding a DNR for
and Turner insisted one was put in place. Dr. Sodden signed a DNR . Dr. Sodden found
out that was placed on in-home palliative care and received heavy doses of
narcotics without the knowledge of the pain management team . Dr. Sodden said that
Turner pressed the issue that ’s quality of life was poor, and it was impacted by her
pain, dependency on TPN and can’t sustain feeding. Turner wanted to withdraw all
medical care and TPN nutrition with regards to . Dr. Sodden said that he didn’t
know if could really tolerate feeds through her GJ tube or not because a separation
test was never done before passed away.

On 06/24/2019, Detective Seaman, Sgt . Denes and Det. Williamson conducted a recorded
interview with Dr. John Bealer. Dr. Bealer is a General Pediatric Surgeon. Dr. Bealer
performed ’s G-tube, Ileostomy and central line surgeries. He was referred by Dr.
Kramer because had a constipation problem , dysmotility and described as a
“challenging diagnosis.” Dr . Bealer described Turner as a “high maintenance mother”
and said that Turner was not afraid of surgery. Dr. Bealer said that with all of the
conditions was being treated for, none of them were terminal and was not a
terminal patient. Dr. Bealer said that death from intestinal failure happens for two
reasons, malnutrition and liver failure. Dr. Bealer said that malnutrition does not happen
in the United States and the liver failure comes from the liver not being utilized during
normal organ functions with a GJ tube. Dr. Bealer explained that the GJ bypasses the
stomach and that liver can’t break down the food and send out the enzymes. Dr. Bealer
said that liver failure occurs years after the GJ tube and said was not anywhere
close to being in liver failure.
On 06/25/2019, Detective Seaman, Sgt. Denes and Det. Williamson conducted a recorded
interview with Dr. Kristen Park (DOB-09/26/1974). Dr. Park is a Pediatric Neurologist.
Dr. Park first treated on 05/28/ 2013 for reports of seizures. Dr. Park said that
was monitored over a time period to see if the “seizure like” activity Turner
described occurred . Dr. Park said that did not have seizures and told Turner to stop
giving the Keppra medication . Dr. Park reviewed MRI scans from Texas
Children’s Hospital and saw there was possible cortical dysplasia present in ’s right
frontal lobe area . Dr. Park did not see that on any other scans that were conducted on
under her care. Dr. Park said that Turner told her ’s medical history and
symptoms . Dr . Park said that Turner would not take off the Keppra medication
and she distinctly told Turner three separate times [July 2014, October 2015 and May
2016] to stop giving the medication to . Dr. Park said that Keppra is not good for
behavior problems, it can cause psychosis, mood swings and other behaviors. Dr. Park
noted that Keppra is taken for a diagnosis of seizures, which did not have. Dr. Park
said that was not a terminal patient.
On 06/ 25/2019, Detective Seaman, and Det. Williamson conducted a recorded interview
-
with Jackie Kammerer (DOB 10/15/ 1983). Jackie is an Occupational Therapist
specializing in feeding and eating. She treated for intensive feeding therapies.
Jackie said that graduated to age appropriate foods, had no problems swallowing
6
or tolerating the foods. Jackie said that completed the therapies without any
problems and did not need to participate in the feeding therapies anymore.
On 06/26/2019, Detective Seaman, t . Denes and Det. Williamson conducted a recorded
-
interview with Dr. Seth Eisdorfer ( Dob 12/04/1978). Dr. Eisdorfer is a Pediatric
Anesthesiologist and the Director of the Chronic Pain clinic. Dr. Eisdorfer treated the
symptoms that Turner reported about being in “a lot of pain .” He said all the
reports of ’s pain and symptoms came from Turner. He said was not a
terminal patient and he was part of the ethics team meetings to discuss the withdraw of
all the medical care received . Dr. Eisdorfer said that Turner was given options
other than withdrawing care, but Turner insisted that ’s TPN and medical care be
withdrawn. The ethics team gave “pushback” on withdrawing ’s TPN care, but it
was ultimately decided to let Turner withdraw TPN nutrition . Turner’s stated reasoning
was because had a life limiting disease and Turner said ’s quality of life was
poor.
On 06/27/2019, Detective Seaman and Det . Williamson conducted a recorded interview
with Dr. Cara Mack . Dr. Mack is a Pediatric Gastrointestinal and Liver Specialist. Dr.
Mack saw twice, the first time was in January 2013 during an emergency room
visit. Oliva was brought in with feeding difficulties and constipation. Turner told her that
had breast feeding complications as an infant and has had feeding complications
her entire life. Dr. Mack noted that appeared to be a normal toddler and within
normal growing ranges. Dr. Mack saw the second time in April 2013 for a follow
up for the constipation. Dr. Mack said was displaying “stool withholding”
behaviors, which is normal in children ’s age.
On 06/27/2019, Detective Seaman and Det . Williamson conducted a recorded interview
with Dr. Thomas Walker (Dob-10/29/1963). Dr. Walker is a Pediatric Gastrointestinal
doctor and clinician . Dr. Walker treated during two in-patient stays at Children’s
Hospital, December 2016 and July 2017. Dr. Walker said that all of ’s symptoms
and medical history came from Turner. He said that did not exhibit the symptoms
Turner described most of the time. Dr. Walker described as very active,
interactive social and fun to be around . Turner reported
, had feeding intolerances
and wasn’t able to eat. Dr. Walker was very vocal against Turner and letting her
withdraw TPN care and all medical care. Dr. Walker said that was not terminal,
and he was against letting Turner take to hospice care to die.

On 07/02/2019, Detective Seaman, Sgt. Denes and Det. Williamson conducted a recorded
-
interview with Dr. Robert Kramer (DOB 12/26/1969). Dr. Kramer is a Pediatric
Gastroenterologist. Dr. Kramer treated starting October 2013 through January
2017. was first seen for constipation problems. Dr. Kramer described as
“social and very talkative” and didn’t think she was autistic. Dr. Kramer did not diagnose
with any of the diseases that Turner wrote about in the GoFundMe page. Dr.
Kramer said that was not a terminal patient and was “shocked” when he heard that
Turner withdrew all medical care and passed away. All of the symptoms and
’s medical history came from Turner.
On 07/02/ 2019, Detective Seaman, Sgt. Denes and Det . Williamson conducted a recorded
- -
interview with Dr. Jaime Belkind Gerson (DOB 09/28/1964). Dr. Belkind-Gerson is the

7
 -
Director of Gastroenterology Program . Dr. Belkind Gerson treated Oliva twice, August
2016 and October 2016. He said that was on full TPN nutrition and described
-
as “always smiling and playful.” Dr. Belkind Gerson said that was not a
terminal patient and he believed that ’ GJ tube,
s ileostomy could be removed , and
could live somewhat of a normal life. He talked to Turner about these options and
Turner refused and said, “it’s already been done.” He was surprised when he heard
passed away and that Turner withdrew all medical care and TPN nutrition.
On 10/11/2019, Det. Williamson conducted a recorded phone interview with Dr. Shaheen
Moshin, a Pediatrician located in Humble, Texas. Dr. Mohsin was and ’s
primary care physician while they lived in Texas. Dr. Moshin confirmed that was
never treated for Non-Hodgkin’s Lymphoma . Dr. Moshin stated that was not
diagnosed with any seizure disorders and was growing appropriately from birth. Dr.
Moshin stated that did have a larger size head , but it was within the normal ranges
for her age. Dr. Moshin stated that might’ve had some developmental delays but
were within the normal ranges for her age.

On 10/ 16/ 2019, Detective Seaman and Det. Williamson conducted a recorded phone
interview with Dr . Gary R. Graham. Dr. Graham retired two years ago, and he was a
physician with Denver Hospice. Dr. Graham stated that he conducted a comprehensive
new patient assessment with on 04/01 /2017. Dr. Graham said that he relied heavily
on the infonnation contained in ’s extensive medical records during his assessment.
Dr. Graham said he viewed ’s past medical history and the history of the present
illness, which was intestinal failure and complete TPN dependency. Dr. Graham noted
Turner as being a primary source of information for ’s medical history. Turner
provided a false medical history for including autism, seizures, hydrocephaly and
numerous birth-related disorders.

COUNT 4-THEFT 1F31

Between and including February 11, 2014 and October 2, 2018, Kelly Renee Turner
unlawfully, feloniously, and knowingly, took a thing of value, without authorization or
by deception namely: US Currency of Medicaid and/or HealthFirst Colorado, with the
value of one hundred thousand dollars or more but less than one million dollars; in
violation of section 18-4-401 ( l ),(2)( i ),(6) C.R .S., and intended to deprive that institution
permanently of its use or benefit; in violation of section 18-4-401( 1 )(a),(2)(i ), C.R .S.

COUNT 5-THEFT ( F4)

Between and including July 27, 2015 and August 23, 2017, Kelly Renee Turner
unlawfully, feloniously, and knowingly, took a thing of value, without authorization or
by deception namely: US Currency and/or services, of GoFundMe and/or Make a Wish
Foundation and/or Professional Miracles Foundation, with the value of twenty thousand
dollars or more but less than one hundred thousand dollars; in violation of section 18-4-
401(1),(2)(h),(6) C.R .S.

8
 COUNT 6-THEFT fF5f

On or about August 24, 2017, Kelly Renee Turner unlawfully, feloniously, and
knowingly, took a thing of value, without authorization or by deception namely: good
and /or services, of Heflebower Funeral Home & Seven Stones Cemetery, with the value
of five thousand dollars or more but less than twenty thousand dollars; in violation of
section 18-4-401( l ),(2)(g),(6) C.R.S.

COUNT 7-CHARITABLE FRAUD ( F5J

Between and including May 17, 2017 and August 10, 2017, Kelly Renee Turner with the
intent to defraud, devised or executed a scheme or artifice to defraud by means of a
solicitation or obtained money, property, or services by means of a false or fraudulent
pretense, representation, or promise in the course of a solicitation . A representation may
be any manifestation of any assertion by words or conduct, including but not limited to, a
-
failure to disclose a material fact, in violation of section 6-16 111 ( 1 )(g) C.R.S.

COUNT 8-CHARITABLE FRAUD (F5)

On or about December 17, 2017, Kelly Renee Turner with the intent to defraud, devised
or executed a scheme or artifice to defraud by means of a solicitation or obtained money,
property, or services by means of a false or fraudulent pretense, representation, or
promise in the course of a solicitation. A representation may be any manifestation of any
assertion by words or conduct, including but not limited to, a failure to disclose a material
-
fact , in violation of 6 16- 11 l ( l )(g) C.R .S.

COUNT 9-CHARITABLE FRAUD - ( ¥ 5 )

Between and including July 27, 2017 and August 23, 2017, Kelly Renee Turner with the
intent to defraud, devised or executed a scheme or artifice to defraud by means of a
solicitation or obtained money, property, or services by means of a false or fraudulent
pretense, representation, or promise in the course of a solicitation . A representation may
be any manifestation of any assertion by words or conduct, including but not limited to, a
failure to disclose a material fact, in violation of 6-16-111 ( l )(g) C.R.S.

COUNT 10-ATTEMPT TO INFLUENCE A PUBLIC SERVANT ( F4J

On or about July 31 , 2013 , Kelly Renee Turner unlawfully and feloniously attempted to
influence a public servant , by means of deceit, with the intent thereby to alter or affect
the public servant's decision, vote, opinion, or action concerning a matter which was to be
considered or performed by the public servant or the agency or body of which the public
--
servant was a member; in violation of section 18 8 306, C.R.S.

9
 COUNT 11-ATTEMPT TO INFLUENCE A PUBLIC SERVANT tF41

On or about November 4, 2013, Kelly Renee Turner unlawfully and feloniously

attempted to influence a public servant , by means of deceit , with the intent thereby to
alter or affect the public servant’s decision, vote, opinion, or action concerning a matter
which was to be considered or performed by the public servant or the agency or body of
which the public servant was a member; in violation of section 18-8-306, C.R.S.

COUNT 12-SECOND DEGREE FORGERY ( Mil

On or about July 31, 2013, Kelly Renee Turner, with the intent to defraud , unlawfully
and falsely completed, or uttered a written instrument , namely: Application for Benefits
from Health First Colorado and /or Medicaid ; in violation of section 18-5-104, C.R .S.

COUNT 13-SECOND DEGREE FORGERY (MU

On or about November 4, 2013, Kelly Renee Turner, with the intent to defraud ,
unlawfully and falsely completed, or uttered a written instrument, namely: Application
for Benefits from Health First Colorado and/or Medicaid; in violation of section 18-5-
104, C.R.S.

The offenses enumerated in in Counts 4, 5, 6, 7, 8, 9, 10, 11, 12, and 13 were

committed in the following manner:

Detective Seaman was assigned on 10/ 12/2018 specifically to investigate financial

aspects of the case as well as assist in general investigation.

Through social media research Detective Seaman was able to determine that Turner
started a blog detailing the medical conditions of and starting on September
27, 2011 . Turner also started a GoFundMe
page, on July 27,2015.

The GoFundMe campaign for solicited donations for assistance in paying for
her medical treatments and final expenses. The campaign consisted of over 100 updates
between July 2015 and August 2017. Many of the medical conditions in the updates from
both pages were inconsistent or exaggerated from what ’s medical records show.
The total of funds raised through GoFundMe, according to the campaign page, was
$22,270 from 161 donors.

Through the GoFundMe campaign , investigators became aware of a “wish” that was
granted to - -
through Make A Wish Foundation on 02/ 17/2017 that was based on
’s reported medical status. Det. Williamson and Detective Seaman met with Make -

10
 -
A Wish Director, Joan Mazak , who provided documents related to ’s wish (Bat
Princess). The documents included financial/expense reports.

Joan told Detective Seaman that Make-A-Wish did not pay for any hotel stays or trips,
only what was related to ’s Bat Princess wish. The wish involved a limousine ride,
costumes, balloons, misc. decorations, props, and location (Hyatt Regency Denver).
was dressed in a Bat Princess costume and essentially had a large party thrown for
her.

- -
The total expenses incurred by Make A Wish were $11,264.88

Detective Seaman also learned , through the Colorado Department of Labor, that Turner
was not gainfully employed and likely had the girls enrolled in the Medicaid Program . He
was able to confirm through the Colorado Medicaid Fraud Investigation unit that and
were both enrolled. The Medicaid Fraud investigator said that a court order would
be needed to obtain copies of the records.

During a meeting with Jeff Gant on 10/24/2017, Jeff told investigators that since before
Turner and the girls moved to Colorado in 2012, he was continuously employed full -
time. Jeff reported taking approximately $300 every two weeks from his paychecks for
living expenses, and depositing the rest, approximately $1800 every two weeks, in a
Wells Fargo Bank account he owned jointly with Turner. Jeff said that he did not use that
money, and that it was for Turner to use for her living expenses.

Based on this information Detective Seaman obtained Wells Fargo Bank records of
accounts belonging to Jeff and Kelly Gant by court order. The records and account
balances corroborated Jeffs account of his deposits and withdrawals. The records also
showed that the accounts were used almost exclusively by Turner based on the number of
transactions completed in Colorado vs. Texas.

Jeff said that he had been continuously employed and that his employers have always
provided health insurance which is available to him and his family. At the time of the
move, Turner and all the girls were covered by Jeffs health insurance. He also said that
while the girls were on his insurance, they were never denied any claims.

A short time after arriving in Colorado Turner contacted Jeff and asked him to remove
her and the girls from his health insurance. She told Jeff that Children’s Hospital made
insurance available that she could buy for a lower cost which would cover everything for
the girls. Jeff believed what Turner was telling him and removed them from his policy.

Through the investigation Detective Seaman has been unable to find that the hospital
provides any form of insurance such as what was portrayed by Turner to Jeff, and it
appears that Turner enrolled the girls in Colorado’s Medicaid program, although Jeff had
health insurance available to cover all of them.

11
Medical records obtained through the course of this investigation indicate that Turner
incurred significant financial liability to Medicaid for the many treatments sought for
and which were incurred from fraudulent information provided to medical
personnel about their medical history.

Detective Seaman obtained Medicaid records from the Colorado Department of Health
Care Policy and Financing by search warrant and learned that Gant completed two
applications for public assistance to include:

Food Assistance
Medical Assistance
Medicaid
Child Health Plan Plus
Tax Credits
-
Colorado Works/TANF Case assistance for Families with Dependent Children

A review of the Medicaid records provided showed evidence of violations of C.R.S. 18-
5-104, Second Degree Forgery, related to the application , and C. R .S. 18-4-401, Theft.

The first application was dated 07/31 /2013 and the second was dated 11 /04/2013. They
were completed electronically with false information provided on each application.

In the 07/ 31/2013 application Turner listed herself as divorced from Jeff Gant who had
employer provided medical insurance coverage available to cover all members of his
family. Jeff was listed as an “absent parent .” She also answered “no” about ever having
used any other name such as a maiden name or alias. Turner also provided her SSN as
instead of her correct SSN of .
In the 11/4/2013 application Turner listed herself as married to Jeff Gant. She
additionally applied for benefits for Jeff and listed him on the application as a Colorado
resident. She listed Jeff as unemployed as of 11/01/ 2013. Turner also claimed on the
application that nobody, including Jeff, had any health insurance benefit or employer
health coverage.

The forms were electronically signed certifying that the statements were true. The e-
signatures “kelly ganf ’ and “kelly r ganf ’ also followed warnings that making a false or
fraudulent statement on her application is a crime in Colorado. The applications
contained dates of birth of all members of Turner’s family, social security numbers,
addresses, children’s schools, and other information indicating that the applications were
completed by Turner. The contact e-mail address provided , country- girl -
78fehotmail.com, is also a known e-mail address used by Turner. Turner also directed all
of and ’s medical care and billing, which resulted in hundreds of claims filed
against Medicaid between February 2014 and November 2018.

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Between 11/04/2013 and 02/ 11 /2014 the Medicaid applications were approved by
Danielle Sworn at Jefferson County DHS. Ms. Sworn is an employee of a public agency,
(DHS) and part of her duties as a public servant are to review and approve such
applications as those submitted by Turner. Medicaid records show that beginning on
02/11 /2014 services received by , and began getting billed to Medicaid.
The last claim shown in the Medicaid records was on 10/02/2018.

There was no evidence that Turner ever amended the information provided to Jefferson
County DHS to reflect Jeffs income, available private insurance or income received
through fundraisers.

Detective Seaman contacted Jeff who said that he never was a resident of Colorado. He
said that his longest visit to Colorado to visit Turner and the girls was approximately 3
weeks. He was employed in Texas the entire time and had employer provided health care
coverage. The insurance would have covered Turner and the girls if Turner had not told
him to remove them from the policy. Jeff reported being covered the entire time by his
employer’s policy.

Detective Seaman worked with Jefferson County DHS Investigator Mara Orley to
determine if Turner was entitled to any benefits and what the overpayment amount
received by Turner was. Investigator Orley conducted an analysis based on bank records
and employment records to determine a total overpayment of MedicaidPM benefits in the
amount of $538,991.67 between March 2014 and December 2018.

A Grand Jury subpoena was served electronically to GoFundMe and GoFundMe

provided 43 pages of documents in PDF fonnat. These records showed that the campaign
was started by an individual by the name of Kelly Gant and that the total amount raised
by Turner was $ 22, 270. All the funds had been transferred from the campaign, but there
was not a record of the receiving bank account. The e-mail associated with the campaign
administrator was country-girl-78@hotmail.com.

-
Detective Seaman learned that a third party company named WePay facilitates transfers
of funds between GoFundMe and receiving accounts. The Gant Wells Fargo accounts,
primarily # , showed multiple deposits from WePay.

A grand Jury Subpoena was sent to WePay for accounts owned by Kelly Gant AKA
-
Kelly Turner or associated with e-mail address countrv girl -78@hotmail.com .

Thirteen pages of Pdf documents and two spreadsheets were returned from WePay
identifying accounts and # as belonging to Turner. Account
was associated with the Peace for Princess campaign. It showed that
all the campaign funds, minus fees, were transferred from the GoFundMe campaign into
Wells Fargo accounts owned by Jeff and Kelly Gant.

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From Wells Fargo Bank records, Detective Seaman became aware of a check from
Professional Miracles Foundation (PMF) in the amount of $3000 that was deposited to
Turner’s account on 08/ 10/2017. Detective Seaman called PMF and spoke to treasurer
Teresa Powers. Teresa said that check was a donation for but did not know if it
was solicited by Turner or by one of the members. She said was referred by Mike
Duggan with Remax. PMF is a foundation that was created by members of the local real
estate industry for the purpose of helping families with very sick children.

Detective Seaman spoke to Mike who said he was initially contacted by an acquaintance
on 05/17/2017, then spoke directly to Turner by voice and text message. He was unable
to retrieve the texts but said he was directly solicited by Turner for help with funeral
expenses. This was prior to 06/ 26/2017, which was when Mike sent a message to PMF
asking for $2700.

On August 9th or 10th Mike personally picked up a $3000.00 check from PMF and
personally delivered it to Turner at Denver Hospice. Mike said he did not have all the
correspondence between him and Turner but would send me what he had .

On 05/ 21 /2019 Detective Seaman received an e-mail from Mike. He initially tried to set
up a ride on the RE/ Max hot air balloon, but around the second week in June it was
decided that was too sick to make it work out. After that Mike reached out to
PMF.

Detective Seaman later reviewed Turner’s Facebook messages and noted that on
06/17/2017 in correspondence with an individual named Bonnie Bruns, Turner sent the
following message [ PDF FB filepg. 27587 ] “Hey Bonnie, hope you are doing well. I
hope you dont mind me reaching out to you but hoping you may have some suggestions.
I met with funeral people yesterday, trying to be proactive with livis arrangements. The
hospice dr came this week said 2-3 months at most . Shes on high doses of meds that arent
helping at all. Anyway, I made most arrangements, picked out plot etc...all that goes
along with this. I had to pay a percentage down for every different piece and then they
allow you to pay off the rest. He told me he could hold the plot I wanted till Monday, but
I needed to bring the payment for it. As you may know, funerals aren’t cheap...in excess
of 14,000. I need 2170 for the plot. So my question was in your business I am sure you
meet lots of people in different areas of life. Was hoping maybe youd know someone
possibly associated with an organization that could help me. If not its ok, just thought Id
reach out and ask ...”

On 06/ 26/2017 Turner also solicited an individual by the name of Coralea Schledewitz
with the following message [PDF FB file pg. 27540] “ Sorry to bother you but Ive been
trying to reach out to anyone who maybe either can help or have suggestions. Almost 2
weeks ago, I met with funeral people. Lots goes into preparing and none of it is easy.
They are willing to work with me on making payments but I am short for the total of the
down payment. Which goes to placing the order for the casket, burial plot , headstone etc.
14
 I

He told me he could give me a week to see if Detective Seaman could get some help,
however some who said they would have not gotten back etc. Detective Seaman have
reached out to some friends in hopes of maybe themselves/business either making a
donation towards it or allowing me to pay back what is borrowed. Anything at all would
help. Funerals arent cheap and Ill be paying awhile I know, but just wondered if you had
any suggestions for me, places to call etc. Im just short 2700 for the total of 7500 they
need for all those things. Any thoughts? I need to be able to let them know today if I can
bring in that difference... appreciate you taking the time to read and anything you think of
please...”

Based on reports from Heflebower Funeral Home and Seven Stones Cemetery, Turner
has not made any payments for any of their services. Turner did provide Hefleboewer
two personal checks from her Wells Fargo account ) in the amount of $410 but
stopped payment on both checks. Invoices were obtained from both businesses and the
final expenses minus interest were:

• Heflebower Funeral Home - $425

• Seven Stones Cemetery - $4973
• Total = $5398
The Heflebower invoice was dated for services on 08/24/2017. The Seven Stones invoice
also showed that payment was to start on 08/24/2017.

AS TO COUNT ONE:
A TRUE BILL A NO TRUE BILL
SIGNATURE REDACTED

AS TO COUNT TWO:
A TRUE BILL A NO TRUE BILL
SIGNATURE REDACTED

AS TO COUNT THREE:
A TRUE BILL A NO TRUE BILL
SIGNATURE REDACTED

AS TO COUNT FOUR:
A TRUE BILL A NO TRUE BILL
SIGNATURE REDACTED

15
 AS TO COUNT FIVE:
SIGNATURE REDACTED A NO TRUE BILL

UNT SIX:
A TRUE BILL A NO TRUE BILL
SIGNATURE REDACTED

^ S TO COUNT SEVEN :
SIGNATURE REDACTED
A NO TRUE BILL

AS TO COUNT EIGHT:
A NO TRUE BILL
SIGNATURE REDACTED

TO COUNT NINE:
A NO TRUE BILL
SIGNATURE REDACTED

AS TO COUNT TEN:
SIGNATURE REDACTED A NO TRUE BILL

AS TO COUNT ELEVEN :
SIGNATURE REDACTED A NO TRUE BILL

AS TO COUNT TWELVE:
A NO TRUE BILL
SIGNATURE REDACTED

AS TO COUNT THIRTEEN :
A TRUE BILL A NO TRUE BILL
SIGNATURE REDACTED

16
 SIGNATURE REDACTED
I , the Foreperson of the 2019 Eighteenth Judicial
District Grand Jury, do hereby swear and affirm that each and every True Bill returned in this
Indictment by the 2019 Eighteenth Judicial District Grand Jury was arrived at after
deliberation and with the assent and agreement to the existence of probable cause by at least
nine members of the 2019 Eighteenth Judicial District Grand Jury
SIGNATURE REDACTED

Subscribed and sworn to before me in the County of Douglas, State of Colorado, the
day of 2019

AMBER COCHRAN
NOTARY PUBLIC NOTARYTUBLIC
STATE OF COLORADO
My Commission Expires: CP j 3" j
NOTARY ID 19964012105
MY COMMISSION EXPIRES JULY « XYM
^
GEORGE H. BRAUCHLER
District Attorney
Eighteenth Judicial District

^ ^ ^
Chnstophpr US llo l , #38191
Chief I jiyfy'District Attorney
Eighteenth Judicial District

The 2019 18 th Judicial District Grand Jury presents the within Indictment, and the same is

hereby ORDERED FILED this Jday of Q$£o hdA^ " , 2019

DGE

WARRANT TO ISSUE

BOND SET AT: NO BOND HOLD

17