gaffey warrant

U1/UJ/~U11 16:18 FAX 860 258 5885 OCSA P.1.0. I4J 001.-----

ARREST WARRANT APPLICATIONJD-CR-S4b R..,v 10"'0e.G.s. § 54-2i'Pr. Bk, See, 36-1, 36-2, 36-~

Police Case number' Agency namt'

STATE OF CONNECTICUTSUPERIOR COURT

www.jud.ct,gov

a.C.S.A. # 2010.0064 D.C.J. - Office of the Chief State's AttorneyN2!ltT'lt' (L8St. Firsl. Middlff 'nitr~1)

GAFFEY, Thomas P.Re.$idence (rown) of aCC\Il;ee

Meriden, CTCOUn:tD

Hartfci .... ..., I Area nUTlbll:r 14

rm, deposes and says

Type/print name 0/ proseculing authority

-----!...:/a~9",,-3"4-'''-''- -----,4 J(eV' j IJ S bo,v I B.....S'-'-A--'- _Affidavit IThe undersigned affiant, being d

1) That the affiant, Inspector Jay St. Jacques, is a duly swam member of the Division of Criminal Justice,assigned to the Office of the Chief State's Attomey (O.C.S.A.), and has over thirty years of experience in thefield of law enforcement and criminal investigation. At all times mentioned herein the undersigned was acting inhis official capacity as a member of the aforementioned agency. The following facts and circumstances arerelated from personal knowledge andlor observations and include infonnnation related to this affiant by fellowofficers and persons w~h knowledge of the facts andlor circumstances contained herein.

2) That Thomas P. Gaffey, DOB 0111011959, of 64-C Nutmeg Drive, Meriden, CT, has been employed by theConnecticut Resources Recovery Authority (CRRA), a quasi-public agency, since December 1988 and currentlyholds the position of Director of Recycling and Enforcement. Mr. Gaffey was elected to the Connecticut StateSenate in November 1994 and continues to represent the 13th District comprised of the towns of Cheshire,Meriden, Middlefield and Middletown.

3) That according to Connecticut State Elections Enforcement Commission (SEEC) archived documents, apolitical action committee (PAC) named "Government Action Fund" (GAF) was registered with the State ofConnecticut On 02101/1999. Thomas P. Gaffey was iisted as the chairperson/candidate, Dennis A. Cenevivawas the treasurer, and Kathleen Gaffey was deputy treasurer. Political action committees may be establishedunder Connecticut election laws on the basis of the committee's political beliefs to support or oppose candidatesandlor ballot questions. The operation of PAC's and their funds are regUlated by Connecticut General Statutesdesigned to ensure two fundamental principles, public transparency and the ultimate accountability falling to thetreasurer.

4) That on December 17, 2003, Thomas Gaffey was interViewed at O.C.S.A. by Inspector Richard J Walshduring the CRRAlEnron investigation. Mr. Gaffey was asked about a 2002 incident whereupon he was c~ed forspending over $10,000.00 in personal expenses, mainly for mileage and cellular telephone usage, on his CRRAexpense account and failing to make timely reimbursements to his employer. Gaffey admitted that he "owed abig balance when it came to light." Inspector Walsh's report indicates that Gaffey explained, "tt1ere was a long

olary PI,1/;!fl(;)

obefore rna on (Oste)

Date

Jurat

(This is page 1 of p 17 pa~8 AffidaVIt)

Finding

The foregOing Application for an arrest warrant, and affidavit(s) altached to said Application, haVing been submitted to andconsidered by the undersigned, the undersigned finds from said affidavit(s) that there is probable cause to beheve thatan offense has been committed and that the accused committed it and, therefore, that probable cause extsts for theissuance of a warrant for the arrest of the abo\le~named accused.Date and Signed at (elry ortawn) On (Dat9)

Si9.alu,., Qr/ll, J-.... (J. j,

Name of J ..dge/Judge Trial REJfI'l,,"e

.J1) J)I2JJJ

ARREST WARRANT APPLICATIONJ~~CFt.64a ~e ..... 10.1QeG.s. § 54-201Pr Bk. S~C. 36-1, 36-2, 36-3

UCSA P.l.O.


WYffl.jud.ct.gov

I4J 002

Name (Last, Fi~l, Middle Initial) ! F{esldence (Tawil) 01 Elccuaed COLIrl to O~ !"IL'lld al (TQwn) . Geogrl\PhlClIil

GAFFEY, Thomas P. Morld.n, CT Hartford. CT i A,." oombe. 14

Affidavit" ContinuedI<lg time in p<lperwork <lnd credit <lfter you paid." When Walsh asked about a possible conflict of CRRA mileageand money paid to a member of the legislature for travel, Mr Gaffey reportedly replied that an aide at thelegislature kept track of his miles for reimbursement. He said he does 'lot go to the LOB (Legislative OfficeBuilding) unless necessary, adding th<lt if he w<lnted to collect that way he could stop there more often. Mr.Gaffey said that a de<ll W<lS ultimately worked out <lnd he p<lid the CRRA back in less than a ye<lr. Th<lt matter.was investigated <It that time by the State Ethics Commission.

5) That the State Elections Enforcement Commission (SEEC) is authorized by Section 9-7b of the ConnecticutGeneral Statutes to inspect the campaign finance reports filed with the Secretary of the State and town clerks,and to audit the accounts or records of the campaign treasurers. As part of the Commission's GeneralAssembly Audit Program for the 2000 election, all senatorial candidates were selected for review, The AuditReport of 'Tom Gaffey for State Senate, Dennis A Ceneviva, Treasurer" prepared by SEEC staff accountantDara M. Haqq On 08/30/2001, covering the period of January 19,2000 to February 13, 2001, cited elevenviolations of regulatory statutes. The violations included failure to provide full addresses of contributors; failureto properly classify the sales of advertisements as contributions; failure to properly identify contributors; failure toprovide <III pertinent det<lils of an expenditure; improper disbursement of surpius funds; failure to provideaggregate amounts received from repe<lt contributors; failure to provide the names of the treasurers ofcontributing political committees; failure to properly code expenditures to secondary payees. Each citationclosed with the accountant's recommendation generally stating, "In the future, please comply with the abovestatutes," or "In the future, please use more care in filling out the form."

6) That the committee "Tom Gaffey for State Senate" was again audited by the SEEC in April 2004, covering theper'lod from January 8, 2002 through February 14, 2003, The Audit Report, prepared by SEEC Accountant DaraM. Haqq, cited seventeen viOlations andlor errors in the campaign fmance reports. The Cited problems includeddiscrepancies in the reporting of contributions resulting in a b<llance shortage of $1 ,650.00; discrepancies in thereporting of expenditures resulting in a balance surpius of $678.26; <I discrepancy in the total amount ofadvertisement purchases reSUlting in a balance shortage of $250.00: receipt of a prohibited in-kind $1,596.38contribution from a business entity; faiiure to provide purpose codes for several expenses; several instances offailing to provide the occupations and names of employers of contributors; failure to provide addresses ofseveral contributors; failure 10 indicate whether several contributions of over $50.00 were made in the form ofcas'h, check or other; failure to disclose the tre<lsurer's name of several contributing committees; receipt of over$1,900.00 in contributions from business entities, a prohibited pr<lctice; sales of advertisement space tobusiness entities in excess of $250.00, making them prohibited contributions; several instances of failing toprovide the nameS and addresses of CEO's of ad space purch<lsers; several instances of failing to provide theaddresses of payees; failure to provide aggregate amounts received from repeat contributors; failure to properlycode expenditures to secondary payees; improper disbursement of surplus funds.

7) That the audit report mandated th<lt the committee treasurer. Dennis A. Ceneviva, file amended statementsrelative to the erroneous monetary amounts within fourteen days of his receipt of the report. The rem<limngcitations closed with the accountant's recommendations, most of them generally slating, "In the future, you arerequired to comply with the above statute."

(This is page 2 of fJ 17 page Afflaavff';Dale

Jurat

UI/UJ/~Ull l(j:l~ !<'AA /j(jU ~51j 5/j1'J5

ARREST WARRANT APPLICATIONJD-CR~4a Rov.10-10C,G,S. § 5tl·2.ePr Bk._ S6c. 36-1, 36-2, 3u.-3

UCSA P.1.U.


'WWW.jUd.cLgov

19J UUJ

N~m~ (las!, Fir:;f, Middle Initial) ResiClence (Town) of accuseCl Court to be <I own Geographical

GAFFEY, Thomas P. Meriden, CT Hartford, CT Ateanumber 14

Affidavit - Continued8) That due to December 2007 media reports concerning questionable SEEC filings of the Government ActionFund (GAF) and alleged possible personal use of campaign funds, SEEC officials conducted an audit review ofthe disclosures of GAF and the disbursements from Senator Thomas Gaffey's Campaigns in 2004 and 2006.Preliminary audit results reflected numerous examples of inaccurate or incomplete filings and evidence ofexpenditures without appropriate disclosure or purpose.

9) That on 01/16/2008 a request was made of the SEEC to authorize a full investigation of the GAF and therelationship to, and transfers between, the GAF PAC and candidate committees for Senator Gaffey. TheCommission initiated an investigation into the expenditures. receipts and campaign fin"nce disclosure reportingof the GAF PAC dating back to 01/01/2004, and the relationship to, and transfers between, candidatecommittees for Senator Gaffey in 2004 and 2006 The investigation was led by SEEC Lead Legal InvestigatorCharles Urso, formerly of the Federal Bureau of Investigation. Much of the information contained in rhis affidaVitis gleaned from Mr Ursa's Report of Investigation dated 11/12/2008

10) That during the review of background information. it was noted that in August 2003 Senator Gaffeyresponded to a Meriden Record Journal inquiry regarding the accounting practices of the GAF. Specifically.Senator Gaffey was asked about the circumstances behind the late reporting of $9,000.00 worth of credit cardexpenditures. The report reflects that the committee stopped providing explanations of credit card purchases in2002. Senator Gaffey acknowledged the omission and commented, "There is potential for peopie to makemistakes and qurte possibly abuse it, but I think you have to make sure you act within the rules and spendmoney appropriately." Senator Gaffey also commented that the GAF cell phones are not for personal use but tofurther the GAF political missiOn to promote Democratic interests and good government.

11) That the first step of the SEEC investigation involved the attempt to recapture all relevant contributions andexpenditures of the GAF. By comparing the entries disclosed in the campaign filings to the records supplied byGAF and Gaffey's 2004 and 2006 Senate campaigns, it became apparent that the disclosures were very sloppy,incomplete and inaccurate. For example, an attempt was made, with the assistance of Supervising AccountsExaminer Dara Howard, to track a $5,259.27 surplus distribution reported from the 2004 Gaffey for Senatecampaign to the GAF on 01/31/2005. No entry could be located on the corresponding filing of GAF On04/07/2005. On 10105/2005 an amendment was submitted for the April 2005 filing by the GAF reflecting areceipt from the Gaffey campaign of $3,694.49. The difference between the $5,259.27 and the $3,694.49($1,564.78) was unexplained and clearly not reconciled. Upon review, it appears that the two figuresrepresented the numbers needed to balance the 2004 Gaffey campaign's SEEC disclosure and the number tonet out the amount remaining in the bank account. In other words, they needed one amount to insure theclosing disclosure statement for the campaign netted out to zero, and a different number was remaining in thebank account to close it out.

12) That on the dates of 02/05/2008 and 07/22/2008 Investigator Urso interviewed Dennis A. Ceneviva, formertreasurer of both the GAF PAC and Thomas Gaffey for Senate committees. Mr. Ceneviva acknowledged thathe was aware and apprised of the SEEC audit findings from the 2000 and 2002 Senate campaigns as describedin paragraphs 5,6 and 7. While discussing committee expenditures, Ceneviva stated that Thomas Gaffey hadtwo personal credit cards (in his own name) that he would use for political purposes in both the GAF· and Gaffey

(This is page 3 at a 17 page Affidsvft )

Jurat

U.l(U')!~U.l.l lO;.l~ .tAA ,!:)bU ;;::::>,!:) :J~1;5 Ul'~A P. j . U . 14JUU4

ARREST WARRANT APPLICATIONJD-CR...E!4a Rev, 1D-'I(Je,G S. § :>4-281Pro B1o:, S~I:, ~6-1, J6-2, 36-3


www.jUd.Cl.gov

N;lrne (l.asl, First, Middle Initial) Re.sid~f'lce (Town) of i'leeused Court to e e i'lt Towrl) Gsographical

_,G=A~F:..:F:..:E=Y.:.c...'T.:.:h:.:.O::m=a=s-:.p_'. [::.M:.:e.:.:rl~d~.n_',:..:C:..:T:..:_ .--.l.I_H_a_rtf_o_rd_',_C_T__.....Li A_'_OO_"_cm_b_"_'_1_4_

Affidavit - ContinuedSenate campaigns, In addition, Senator Gaffey maintained a cell phone account in his name. Ceneviva Initiallyexplained that Senator Gaffey would provide the credit card bills to Ceneviva's office and Debra Mischler, anemployee of Ceneviva's, would obtain underlying, secondary payees as well as the campaign purpose and paythem from the GAF checking account. (Investigator Urso later learned that Mr. Ceneviva was mistaken in thatSenator Gaffey only telephonically reported the expenditures to Mischler,) Senator Gaffey retained thesupporting documentation because the credit cards and cell phone were in his own name and 110t that of theGAF,

13) That Ceneviva provided records (white sheets) outlining the expenditures for the GAF from 2004 to 2008,Senator Gaffey prepared these white sheets, based on his credit card expenditures, in 2008 in response to theSEEC inquiry to serve as a guide to identify the items. The entries were not necessarily supported bycontemporaneous information within the supporting documentation of the GAF or Senate campaigns as SenatorGaffey retained the supporting documentation at the time of payment.

14) That Ceneviva employee Debra Mischler was also interviewed by SEEC Investigator Urso on 02/05/2008and 07/22/2008. Mischler had a disclosed role in the Senate campaigns as Deputy Treasurer. She did not havea registered role with GAF during the period reviewed, but stated that she acted as if she did. Mischler reportedthat Senator Gaffey would customarily contact her and verbally advise her of the amount needed to be paid forthe credit card and cell phone bills without supplying underlying invoices. Senator Gaffey would designatewhich expenses or proportions were campaign related. After speaking with the Senator, Mischler would post thesecondary payees and, occasionally, the campaign purpose on the check register, Mischler acknOWledged thatthese expenses were paid without seeing the supporting documentation. She would retain the addresses andaccount information, prepare the checks and give them to Ceneviva to sign and mail out. Mischler said that shewould tI1en transpose the payment information to the SEEC disclosure filings, She would occasionally get acopy of an invoice for an expenditure, but that would only happen some months later. Mischler reported thatshe was only aware of one of Senator Gaffey's credit card accounts, that being the AAA Financial Services card,and did not recall ever being aWare of his other credit card account from Sears,

15) That Investigator Urso interviewed Ms, Robin Havelin regarding her role at the Legislature relative toSenator Gaffey'S travel requests,. Ms, Havelin reported that she's been Senator Gaffey's Legislative Aide since2001' and has helped on the Senator's candidate campaigns ever since. At the direction of Senator Gaffey,Havelin would fiU out the travel requests when the Senator indicated that he was going to attend a conferenceHavelin would list the expenditures allowed for a conference and forward the request for approval. She wouldalso contact the conference, register the Senator and book the hotel accommodations. Havelin would routinelyuse a Gaffey credit card to pay for the expenses. Havelin reported that she didn't pay attention to excessexpenditures (SUCh as upgrades) reflected on the invoices supporting the travel vouchers because anyreimbursement was limited to the allowable and original approvaL She understood that all conferenceregistration fees were paid for by Legislative Management and didn't have any idea that the GAF PAC was alsopaying those expenses. Ms. Haveiin stated that she was added as the Deputy Treasurer of the GAF PAC inMay 2007 in case she had to sign something, but never did,

Oste

fb. /0

I SIQl"led (Affiant!

m9 on (Datfl)Jurat

16} That during the course of Investigator Urso's SEEC probe, it became evident that Ms. Patricia Murphy, a

(This IS page 4 of a 17 page AffldsVlt.)DOItl':

Ul,~A t',l.U. tm UU5

ARREST WARRANT APPLICATIONJO-CR-64a Rev 10-10C G.S § 54-2aPr, Bk, Sec, 36-1, 31S~2, 36-3


Io'MW.Jud.ct.gov

NSI>,e (Las!, I"1f"$1, Middle /rJitiill)

GAFFEY, Thoma.. P. IF{elil~ef1C~ (Towrl) of l!le.tu,.rd

Meriden, CT Hartford, CTIHY'!'! Geographical

\ Area numtler 14

Affidavit - ContinuedDemocratic town committee chair in Meriden, CT. with whom Senator Gaffey maintained a personal relalionshlp.may have inappropriately received benefits paid for by the GAF, the State of Connecticut, or both Upon beinginterviewed by Mr. Urso on 08/21/2008. Ms. Murphy acknowledged that she had a personal relationship withsenator Gaffey from November 2002 to September 1,2007. She was unfamiliar with Senator Gaffey's politicalaction committee (PAC) until Senator Gaffey mentioned to her that the PAC pays for some political expenses.Murphy stated that she never asked to have a role, playa part or receive any benefit from the PAC and she wasunaware that she might have. She had heard of the name "Government Action Fund" (GAF) and believed thatwas Senato. Gaffey's PAC.

17) That Ms, Murphy stated that there were a number of conference-type trips on which she accompaniedSenator Gaffey. Prior to the first t~p, which was to San Francisco, Senator Gaffey asked her if she wanted to gowith him. When Murphy told the Sonator that she could not afford the cost of the trip he told her that the PACwould pay his share and that he would pay for her. That was the premise under which she operated andunderstood was taking place on their trips to San Francisco, Salt Lake City, Seattle, Nashville, Tampa and twiceto Washington, DC. Ms. Murphy said that she did not attend any of the conterence proceedings except to seeGaffey speal\. She told t.:rso that there was no political purpose to her accompanying the Senator on the trips.She went as Senator Gaffey's companion and they often had opportunities to do personal side-excursionsincluding a whale watch in Victoria during the Seattle trip.

18} That PatriCia Murphy told Investigator Urso about a conversation she had with Senator Gaffey regarding hercell phone. At the time 01 the conversation, she was spending about $3500 per month on her cellular serviceand she considered canceling it. Senator Gaffey told her that he had a cell plan on wnlch he wasn't using all ofthe minutes. so he offered to provide her with a phone On that account because he didn't want her to be withouta cell phone Murphy stated that Gaffey told her that h... would charge the political stuff to th... PAC and he wouldpay the remainder. Ms. Murphy estimated that S...nator Gaffey provided her with the cell phone for about oneand-a-haI1 to 'coNo years until November of 2007 when he shut off the service.

19) That upon encountering business expenditures, Mr. Gaffey had available to him three averues to obtainreimbursement hased on he nature of the expense. Those avenues are described as:

a) CRRA business-related expenses could be recovered by filing the appropriate pap...rwork withhis full-time employer. the CRRA, with whom he had a travel expense account and companycredit card;

b) The Senator could be reimbursed for political expenses, as allowed by statute, by his political actioncommittee (PAC);

cJ Travel-related expenses associated vllth the Senator's duties as a member of the State legislature could bereimbursed by tile State of Connecticut Office of Legislative Management.

,

SIgned (AHlsnI)

o

20) That during his investigation, SEEC Investigator Urso noted that a number of GAF exp...nditur...s appeared tobe related to official functions attended by the Senator. KnOWing that the expenses incurred to attend thesefunctions were reimbursable by the Office of Legislative Management, Mr. Urso requested copies of SenatorGaffey's State travel expense records. In comparing reimbursed expenses from both the GAF PAC and the

(Thi$ ,-~' pege 5 of 8 17 p:ilge Aflldavlt.)

Jurat

lIJ.f lIJI -'lI.1.1 .10;':;U 1'1\"\ OOU Z<>O <>OO:J UC:lA t'. 1. U. 1m UUb

ARREST WARRANT APPLICATIONJD-CR-MOli ReI!, 10w10e.G,s. § S4w2aPro Bk. Sec. 'J8w1, 35.2 30,3


WW'N.jud,t:\ gol,'

N.u'ne (I.a:/. FI'3r, Mlddl8 Iml/el) Re:5idl!ll'lce (Town) of <l{;l;ll~ed Court to be Mid at own) Geogra,ol'lICB(

GAfFEY, Thomas P. Meriden, CT Hartford, CT Are;" rWl1,ber 14

Affidavit· ContinuedOffice of Legislative Management, it was determined that on several occasions Senator Gaffey had been twicereimbursed for the same expenses.

21) That Senator Gaffey, accompanied by Patncia Murphy, attended the National Conference of StateLegislatures' Annual Meeting in Salt Lake City, Utah, from 07/18 through 07/23/2004. Review of the documentsin the SEEC investigative file indicate the following:

05/17/2004 - Sen. Gaffey charged $389.39 ($349.39 for tickets plus the $40,00 travelagent's fee) to his AAA Financial Services Visa account #XXXX-XXXX-XXXX-5586 forAmerican Airlines round trip airfare to Salt Lake City, UT.

05/17/2004 - GAF PAC submitted payment of $493.20 to Sen, Gaffey's AAA Financial ServicesVisa account #XXXX-XXXX-XXXX-5586 via Hudson United Bank account #XXXXXXX748,check #1166, This payment included the full amount of $389,39 for the Salt Lake Cityairfare charged to Senator Gaffey's credit card earlier that day, Documentation forthis reimbursement was not submitted contemporaneously and, according toCeneviva and Mischler, was probably proVided based on a verbal request. (Seeparagraphs 12 & 13,) The "White sheet" documentation of this expense was providedby Senator Gaffey in 2008 in response to the SEEC investigation.

07/15/2004 - A Leglsliliive TraJLel.Bi:!qu.e.s.LEurm was submitted to tile Office of LegislativeManagement on behalf of Senator Gaffey. The form lists the anticipated cost of theSalt Lake City trip as $1,429.89, Which included the airfare of $349.39

0810212004 • A Slate of Connecticut Employee YQ~herlTravel and Othes.i'XQenses Incurred in theService of the State of Connecticut signed by Senator Thomas Gaffey, was submittedto the Office of Legislative Management The voucher sought reimbursement toSenator Gaffey for expenses incurred to attend the NCSL annual meeting in Salt LakeCity. UT InCluded in the expenditure list was the amount of $36939 for airfare,Senator Gaffey's itinerary receipt and a heaviiy redacted copy of page one (page twonot included) of his AAA Financial Services credit card statement were attached assupporting documentation. It is noted that the only half of the $40.00 travel agent's feewas listed for reimbursement by the State, suspected to be the prorated amount basedon the purchase of two tickets (Gaffey and Murphy) on the same transaction.

08/18/2004 • Senator Gaffy's Employee Voucher was approved in the amount of $2,161.68.including the airfare for $369,39, and reimbursement was included in hisregUlar paycheck on 09/30/2004,

The above-described actions resulted in Senator Gaffey receiving duplicative reimbursement in the amount of$369.39.

22) That Senator Gaffey attended the Council of State GovernmentslEastern Regional Conference (CSG/ERC)annual meeting in Montville. CT, from 07/25 through 07/28/2005. Review olthe documents in the SEECinvestigative file indicate the following:

lit

SigrJ

to before me on (Di]~)

Jurat

(Tflfs is page 6 of a 17 page Affidavtr.)

Dale r- ~~~c_ 20

U~/Uv/~U~~ ~o:~u ~AA ~UU ~5~ 5885 OCSA P. I. O. I4i 007

ARREST WARRANT APPLICATIONJO·CA.d4s "eV' '0-'0e.G.s Ii 54-2~Pr. Elk. Sec. 36-1, 36.2, 36.3


WYIW.jud.ctgov

GeographicalArea r,umb4r 14

ourt to l;l ~Id.\ (Tow")

Hartford, CTi Meriden, CTNilflle (Lnr Firnr, Middle Imrlal)

GAFFEY, Thomas P. __________-.L-"-_~~ ___'______'_~_ ___L ~

Affidavit· Continued06/02/2005 - A Legislative Travel Request Form was submitted to the Office of Legislative

Management by Senator Gaffey. The form lists the anticipated cost of theMontville trip as $972.24, which included the registration fee of $250.00.

06/16/2005 - Sen. Gaffey charged $100.00 to his AAA Financial Services Visa account #XXXXXXXX-XXXX-5586 for the Council of State Governments registration fee for theannual meeting in Montville, CT

07119/2005 - The Office of Legislative Management issued payment directly to the Council of StateGovernments ($250.00 registration fee), as well as to the hotel ($534.24, three ni9htsat $178.08/night).

12/07/2005 - GAF PAC submitted payment of $661.05 to Sen. Gaffey's AAA Financial ServicesVisa account #XXXXX-XXXX·XXXX-5586 via Hudson United Bank account #XXXXXXX748,check #1214. $100.00 of this payment was reported as being for the Council of StateGovernments registration fee for the annual meeting that took place in July.

The above-described actions resulted in Senator Gaffey receiving duplicative reimbursement in the amount of$100.00

23) That Senator Gaffey, accompanied by Patricia Murphy, attended the National Conference of StateLegislatures' Annual Conference in Seattle. WA. from 08/16 through 08/20/2005 Review of the documents inthe SEEC investigative file indicate the following:

O(<Jry P\!/;;i!~)

2. C 10

03129/2005 - Sen. Gaffey charged $653.55 ($639.56 for the two tickets plus the $13.99 Orbitz fee)to his Sears Gold MasterCard account #XXXX-XXXX-XXXX-3143 forDelta Airlines round trip airfare to Seattle, WA.

04108/2005 - A bf!..Qi"-'.aliv,e Ir.ay_e.l ReQUest Form was submitted to the Office of LegislativeManagement by Senator Gaffey. The form lists the anticipated cost of theSeattle tnp as $2,115.82, which included the Sanditz Travel airfare of $448.00.

05/0912005 - GAF PAC submitted payment of $326.78 to Sen. Gaffey's Sears Gold MasterCardaccount #XXXX·XXXX-XXXX-3143 via Hudson United Bank account #XXXXXXX748,check # 1187. This payment covered one of the Delta airlines tickets ($319.78) plushalf of the $13.99 Orbitz fee ($6.99) charged to Senator Gaffey's credit card on03/29/2005. Documentation for this reimbursement was not submittedcontemporaneousiy and, according to Ceneviva and Mischler, was probably providedbased on a verbal request. (See paragraphs 12 & 13.) The "white sheet"documentation of this expense was provided by Senator Gaffey in 2008 in responseto the SEEC investigation.

09/02/2005 - A State of Connecticut Employee V..QucherlTravel and Other Exp,enses Incurred in theService of the State of Connecticut, signed by Senator Thomas Gaffey, was submittedto the Office of Legislative Management. The voucher sought reimbursement toSenator Gaffey for expenses incurred to attend the NCSL annual meeting in SeattleWA. Included In the expenditure list was the amount of $326.77 for airfare.A copy of Senator Gaffey's Orbitz flight reservation, with the second traveler's name

(ThiS is page 7 of a 17 pag8 Affidavlr.)Dsta

Jurat

R.,/.W.dF0 ~.I) -----l!F4~~(Q_L ___'=J!!~!:=f-----------w.~2!!Jl.L!!--

ARREST WARRANT APPLICATIONJD-CR~"';lI Rev_ 10.10e,G,S. § 54-28Pro Bk. Sec. 36·1, :!6.~, 38.3


www.jud ct.gov

tm UUM

Nil:me (la3/. FlrSI. M/(Jdle Inltisl) RSI3IC1enca (Town) or ,,~cused Court to b", held at (Towtl) Geographical

GAFFEY, Thomas P. Meriden, CT Hartford, CT M" cumb" 14

Affidavit - Continuedredacted, was attached as supporting documentation. The amount of $326.77represented the cost of one airfare plus half of the Orbitz fee.

09/15/2005 - Senator Gaffy's Employee Voucher was approved in the amount of $1 ,834,58,including the airfare for $326.77, and reimbursement was included in his regularpaycheck on 10/31/2005.


24) That Senator Gaffey, accompanied by Patricia Murphy, attended the National Conference of Statelegislatures' Education Finance Seminar in Tampa, FL, from 02/16 through 02/19/2006. Review of thedocuments in the SEEC investigative file indicate the following:

01/05/2006 - Sen. Gaffey charged $913.20 (two round trip tickets at $456.50 each) to his AMFinancial Services Visa account #XXXX-XXXX-XXXX-5586 for Delta Airlines airfare fromHartford to Tampa, departing on 02/16/2006.

02/03/2006 - A Legislative Travel Request Form was submitted to the Office of LegislativeManagement by Senator Gaffey. The form lists the anticipated cost of theTampa trip as $1,816.20, which included one Delta Airlines ticket, described above,and the $300.00 NCSL seminar registration fee.

02/10/2006 - GAF PAC submitted payment of $630,60 to Sen. Gaffey's AM Financial ServicesVisa account #XXXX-XXXX-XXXX-5586 via Hudson United Bank account #XXXXXXX748,check # 1222. This payment covered one of the Delta airlines tickets ($456.60)charged to Senator Gaffey's AM credit card on 01/15/2006. Documentation for thisreimbursement was not submitted contemporaneously, but Senator Gaffey's "whitesheet" documentation, as well as a copy of that page of his credit card statement. wasprovided in 2006 in response to the SEEC investigation.

03/10/2006· A State of Connecticut Employee Voucher[Iravel and Other Expenses Incurr:.e..d...in...tbslService of the State of Connecticut, signed by Senator Thomas Gaffey, was submittedto the Office of Legislative Management. The voucher sought reimbursement toSenator Gaffey for expenses incurred to attend the NCSL Education Finance SeminarIn Tampa, FL. Included in the expenditure list was the amount of $456.60 for airfareA faxed copy of Meriden Travel Bureau, Inc. receipt # 116624, issued to Sen. Gaffeyfor the amount of $456.60 and dated 03/30/2006, was submitted at some point assupporting documentation for the airfare expense.

04/03/2006 - Senator Gaffey's Employee Voucher was approved in the amount of $1,161.24,including the airfare for $456.60, and reimbursement was included in his regularpaycheck on 05/31/2006.

05/15/2006 - An NCSL invoice was sent to Senator Gaffey indicating that he owed them the$300.00 registrallon fee for the Education Finance Seminar.

OS/24/2006 - Notations on the copy of the NCSL invoice, above, provided to the SEEC by OLM,indicate that Office of Legislative Management paid this invoice as an addendum to

(ThiS is paglJ B of a 17 page AffidaVIt.)

Date

Jurat

ARREST WARRANT APPLICA TIONJD-CR.fi4s Rev 10-10C G.S. § 54-=!;3Pro Sk.. Se~ 315-1, 36-2, 38.3


'tMW.jud.cl.gov

li1J uu~

Name (La~t, First, Middle }r1itial) Rl::$;dencf' (town) of ~I:cu:!led

GAFFEY, Thomas P. Merldan, CT

Affidavit - Continuedthe original travel request (TR # 472),

Court to c held ~l (Tl"Jwn) I Geog...phlc:al

I Hartford, CT I Afl;:<1 nurnb~r 14


25) That Senator Gaffey, accompanied by Patricia Murphy, attended tile National Conference of SlateLegislatures' Annual Meeting in Nashville, TN. from 08/14 through 08/18/2006. Review of the documents in theSEEC investigative file indicate the following:

04/25/2006 - Sen. Gaffey charged $542.20 (two round trip tickets at $271.10 each, plus fees) to hisAP-A Financial Services Visa account #XXXX-XXXX-XXXX-5586 for Southwest Airlinesairfare from Hartford to Nashville, departing on 08/15/2006,

05/26/2006 - GAF PAC submitted payment of $625.46 to Sen Gaffey'S AAA Financial ServicesVisa account #XXXX-XXXX-XXXX-5586 via Hudson United Bank account #XXXXXXX748,check # 1240. This payment covered one of the Southwest Airlines tickets ($271.10)charged to Senator Gaffey's AAA credit card on 04/25/2006. Documentation for thisreimbursement was not submitted contemporaneously, but Senator Gaffey's "whitesheet" documentation. as well as a copy of that page of hiS credit card statement, wasprovided in 2008 in response to the SEEC investigation,

06/2212006 - A LegWatjve Travel Request Fonn was submitted to the Office of LegislativeManagement by Senator Gaffey. The form lists the anticipated cost of theNashville trip as $1,684.14, which included one Southwest Airlines ticket ($271,10), theNCSL conference registration fee ($450,00). hotel ($716,00) and other incidentals,

07/21/2006 "Senator Gaffey charged $150.00, that he later indicated was for the NCSL conferenceregistration fee, to his AAA Financial credit card.

08/10/2006 - GAF PAC submitted payment of $663.42 to Sen. Gaffey'S AAA Financial ServicesVisa account #XXXX-XXXX-XXXX-5586 via Hudson United Bank account #XXXXXXX748,check # 1248. This payment included reimbursement of the $150,00 NCSL registrationfee charged to Senator Gaffey's AAA credil card On 07/21/2006. Documentation forthis reimbursement was not submitted contemporaneously, but Senator Gaffey's "whitesheet" documentation. as well as a copy of that page of his credit card statement, wasprovided in 2008 in response to the SEEC investigation.

08/18/2006 - Senator Gaffey charged $988.02, that he later indicated was for his entire GaylordOpryland Hotel bill, to his AAA Financial credit card Also charged to the Senator'scredit card was the $27.04 Avistar/Bradley Airport parking fee,

09/11/2006 - GAF PAC submitted payment of $1 ,015,06 to Sen. Gaffey's AAA Financial ServicesVisa account #XXXX-XXXX-XXXX-S586 via Hudson United Bank account #XXXXXXX748,check # 1251. This payment was for reimbursement of the $988.02 Opryland GaylordHotel bill as well as the $27.04 Bradley airport parking fee that Senator Gaffey chargedto his AAA credit card on 08/18/2006. Documentation for this reimbursement was notsubmitted contemporaneously, but Senator Gaffey's "white sheet" documentation, aswell as a copy of that page of his credit card statement, was provided in 2008 in

UC~A P.l.O. 411010

ARREST WARRANT APPLICATIONJO..cR~4;;r, Rev, 10-10C G.S. § 54-2aPro Bit Sec, 36ft' J6.2, 38-.3


W"WW.jud c~.gov

Name (Lssr, Flnlt. MIddle /nlll~l) Residence (Town) 01 accu!ed ourt 10 6 aid at (Town) GMgrsphlelitl1

~G=A:...::..-F:.-FE=-Y.:-,,-T..h:=a..m:.::a::::s::..:..P.:.. I..::M::.:•..::rl::d::..en..::•..:C:..:T ~H..:a..:rtf:..:a=_r..:d..:, ..:C..:T ~Ac~••~"~"m_o_.,_1_4_Affidavit - Continued

response to the SEEC investigation.11/01/2006 - An NCSL invoice was sent to Senator Gaffey indicating that he owed them the $450.00

registration fee for the 2006 NCSL Annual Meeting.11118/2006 - A State of Connecticut Employee VOuchItl:O:r.aY.e.l and Other Expenses Incurred in the

Service of the State of Conoecticut, signed by Senator Thomas Gaffey, was submittedto the Office of Legislative Management The voucher sought reimbursement toSenator Gaffey for expenses incurred to attend the NCSL Annual Meeting in Nashville,TN Included in the expenditure list was the amount of $271.1 0 for airfare. $613.26 forthe hotel and $25,00 for parking at Bradley Airport Submitted to OLM as supportingdocumentation was the Gaylord Opryland Hotel receipt for $988.02 and the SouthwestAirlines receipt as issued to the Senator on 04/25/2006.

11/21/2006 - Natations on the copy of the NCSL invoice dated 1110112006, above, provided to theSEEC by OLM, indicate that Office of Legislative Management paid this invoice as anaddendum to the original travel request. (TR # 578).

0111912007 - Senator Gaffey's Employee Voucher was approved in the amount of $1 ,07326,including the airfare ($271.10), the hotel ($613,26) and the Bradley parking fee($25.00). The Senator's reimbursement was inclUded in his regular paycheck on02/28/2007.

07/2012007 - Senator Gaffey's personal AAA Financial Services credit card was refunded the$150.00 NCSL registration fee that he submitted on 07/21/2006 for the 2006 NCSLAnnual Meeting. (The actual registration fee amount of $450.00 was paid for by OLMon 11/21/2006.)

The above-described actions resulted in Senator Gaffey receiving duplicative reimbursement in the amount of$1,209,36.

26) That Senator Gaffey attended the No Child Left Behind (NCLB) meeting at the White House from 03/22through 03/23/2007. Review of the documents in the SEEC investigative file indicate the following:

oO,te

03/19/2007 - A Legislative Travel Requll.:tl£prm was SUbmitted to the Office of LegislativeManagement by Senator Gaffey, The form lists the anticipated cost of theWashington, DC, trip as $964.80, which included one night's lodging at $299.99,

03/23/2007 - Sen. Gaffey charged $449,19 to his AAA Financial Services Visa account #XXXX-XXXXXXXX-5586 for the one night's stay at The Hotel George in Washington DC. The totalamount due consisted of the room charge ($299.00), tax ($43.36) and miscellaneouscharges at the "bistro" ($106.83).

05/10/2007 - GAF PAC SUbmitted payment of $449.19 to Sen. Gaffey's AAA Financial ServicesVisa account XXXX-XXXX-XXXX-5586 via Hudson United Bank account #XXXXXXX748,check # 1274. This payment was for reimbursement of the entire $449.19 HotelGeorge bill of 03/23/2007. Documentation for this reimbursement was not submittedcontemporaneously, but Senator Gaffey's "White sheet" documentation, as well as acopy of that page of his credit card statement, was proVided in 2008 in response to the

(ThiS is page 10 of a 17 p;Jge Affidavit.)Oa~",

v ...... ... VI "'''.1..1. -'.V .... ..1. rl'iA ()UU ;;'.;)0 ;;00;; 14]011

ARREST WARRANT APPLICATIONJD_CR_64;;a Ro;v, 10-'0CG S § 54-2E!?r. ~k, Sec, 38-1, :lB-2, 36-3


\NVJIN.jud.ct.gov

Geographical, Are~ number 14

ourt to be elt:l at r own)

iHartford, CTI

Residence (Town) ot accu,etl

Meriden, CT---~---

N;orno (LtI~l. Firsr. MiddlfJ InltlBI)

GAFFEY, Thomas P.

A.ffidavit • ContinuedSEEC investigation.

06/27/2007 - A State of Connecticut~ee VoucherfTravel and Other E;rnenses Incurred in the.Service of the State of Connect(p_u1. signed by Senator Thomas Gaffey. was submittedto the Office of legislative Management. The voucher sought reimbursement ofSenator Gaffey for expenses incurred to attend the No Child left Behind meeting inWashington DC. Included in the expenditure list was the amount of $342.36 for theroom and tax. Submitted to OlM as supporting documentation was an itemized copyof the Hotel George receipt.

07116/2007 - Senator Gaffey's Employee Voucher waS approved in the amount of $461.15,inclUding the hotel charge of $342.36. The Senalor's reimbursement was included inhis regular paycheck on 08/31/2007.

The above-described <lctions resulted in Senator Gaffey receiving duplicative reimbursement in the amount of$342.36.

27) That Connecticut General Statute § 9-507 provides, in relevant part

(g) Permissible expenditures. (1) As used in thiS subsection, (A) "the lawful purposes of his committee"means: (i) For a candidate committee or exploratory committee, the promoting of the nomination or election ofthe candidate who established the committee, except that after a polilical party nominates candidates forelection to the offices of Governor and Lieutenant Governor, whose names shall be so placed on the ballot inthe election that an eiector will cast a single vote for both candidates, as prescribed in section 9-181, acandidate committee established by either such candidate may also promote the election of the other suchcandidate; (ii) for a political committee, the promoting of the success or defeat ofcandidates fornomination and election to pUblic office or position subject to the reqUirements of this chapter, or thesUccess or defeat of referendum questions, provided a political committee formed for a single referendumquestion shall not promote the success or defeat of any candidate, and provided further a legislative caucuscommittee may expend funds to defray costs of its members for conducting legislative or constituencyrelated business which are not reimbursed or paid by the state; and (iii) for a party committee, thepromoting of the party, the candidates of the party and continuing operating costs of the party, and (B)"Immediate family" means a spouse or dependent child of a candidate who resides in the candidate's household.

28) That on 05/28/2008 Investigator Urso interviewed Senator Gaffey. The Senator acknowledged that he wasaware of the SEEC audit findings from the 2000 and 2002 Senate campaigns as described in paragraphs 5, 6and 7. Senator Gaffey indicated that after he saw the Hartford Courant artiCle of 12/02/2007 alieging thepossible personal use of PAC funds, he examined some of his campaign filings to confirm that expenditureswere reported appropriately. When the author of the newspaper article, Mr, Kevin Rennie, raised questionsrelative to a trip to Washington DC, Gaffey realized that he had been reimbursed by both the State and the GAF.He ordered that all GAF-paid travel expenses be reviewed, He started reviewing the Items in December 2007and January 2008. On 12/11/2007 he reimbursed the GAF some of the funds that had been disbursed on hisbehalf and pointed to an $870.00 entry. Gaffey acknowledged that the amount was refiected in the summary,but not outlined or explained in the filing. Without proper itemization and disclosure, it was not discernable in the

(This Is page 11 of a 17 page Affidavit.)Dala

(, 7)cc. 2 <:l <), C D~Ub!tti"ed and!> m to l>oM re me en (Oaf<:l) ::Jry Pl)olic)

Juri!t' . -2. .

Ul,;:'1\ r.l.U.

ARREST WARRANT APPLICATIONJO.CR.&4a RIO" 10·'0C G.S § S4-2t!.Pr Bll'., Sec.. 313-',36-2,35-3


................jud.cI.90v

ourt to e held 31 (TOwn) Geogfsphic8'

I Hartford, CT Area number 14Rell.lClNlce (Town) of accused

I Meriden, CTNamE! (L~!ot, ~irs(, Middlft Inltts/)

GAFFEY, Thomas P.

Affidavit - ContinuedSEEC statement as reimbursement of National Conference of State Legislatures (NCSL) expenditures. Gaffeybelieved that a $456.00 tnp-related to payment for Patncia Murphy to attend an event was one of the items notrepaid. Gaffey explained that Murphy was involved in "politically related stuff."

29) That Senator Gaffey acknowledged that items paid for by State voucher through Legislative Managementshould not have been also paid by the GAF PAC. He stated that anything paid for by the Legislature can't bepaid twice and you cannot "dOUble-dip." Gaffey acknowledged that the GAF should have been paid back andthat prior to the Rennie newspaper article, he had not made any reimbursement for any other trips or expensespaid for by both the GAF and the LegiSlature. Gaffey also admitted that because of the way the records weremaintained and reported, he was the only one who would have been able to Know that expenses were beingpaid twice. There simpiy was not sufficient documentation in the possession of the people paying obligations ofGAF or Legislative Management to make that determination. Gaffey acknowledged that few, if any, documentswere proVided to Ceneviva or Mischler to substantiate the lawful and political purpose for the GAF expendituresat the time the GAF expenditures were authorized by him. During the interview, Senator Gaffey's attorney. Mr.Tnomas Luby, cited two additionai items that were identified during their attempt to clarify and addressexpenditures that had been paid twice. Attorney Luby indicated that Senator Gaffey made reimbursements tothe GAF in January 2008 in the amount of $722.00 for a trip to Nashville in August 2006 (entry reported on04104/2008) and in May 2008 in the amount of $456.60 for a trip to Tampa in 2006. Both of thesereimbursements were reported in the July 2008 SEEC filing.

30) That On or about 01/28/2009 the Meriden-Record Journal published an article written by then RecordJournal staff reporter Amanda Falcone titled. "Records Detail Gaffey's PAC Use, Double-Billing for Hotels." Thearticle reported on the observations of Record-Journal staff who had reviewed State records Cited as beingreViewed by the SEEC investigation which was pending at the time. Questionable actions by Senator Gaffeycited in the article included:

a) Staying at "posh," upgraded hotel rooms on numerous occasions. receiving allowable travel reimbursementsfrom the State Office of Legislative Management, and then receiving reimbursements for the difference fromthe GAF PAC.

b) Receiving reimbursements from the GAF PAC for additional days spent at the hotels beyond the end of theassociated conferences.

cJ Submitting for reimbursement from the State for nights spent in the hotels beyond the end of the associatedconferences.

d) Being twice reimbursed for the same expenditures by both the State Office of Legislative Management as wellas the GAF PAC.

20'~

Jurat

The article reads, "Gaffey says he used his PAC to pay for one additional night in Seattle because he attended aDemocratic leadership council luncheon. He paid for the extra nights out of hiS own pocket, he added, notingthat billing the State for a fifth night must have been an error made by staff when the paperwork was submitted.Gaffey. however. signed off on the forms." In addressing the issue of staying in a more expensive hotel room($359.00/night) in Nashville rather than the less expensive ($179.00) room that would have been fUllyreimbursed by the State, Falcone reported, "Upon arriving at the resort, Gaffey says, Murphy was ill, so they

(This Is page 12 of a 17 paQtJ Affidavit,)

DB~e "-.L)-Fi

U\.,,:)i\ t'. 1. U. IQjU13

ARREST WARRANT APPLICATIONJO-CR-64a Rev 10-10C,G.S, § 54-2ePro 81(. Sec, 36_1, 35-2, 3&-3


wwwjud,cl,gov

Name (Ls&t fOil'Sl, Mlcd/Q InitiBI)

GAFFEY, Thomas p.RMltlence (TC1wn) of ilCCIJ6ed

Meriden, cTCUrl to be MId ;Ilt (Town) Geograpt11Cal~~

Hartford, CT Area !lumber 14

Affidavit· Continuedtook the first room available - a suite at the discounted rate of $233.65 per night, which, Gaffey added, was notthe fancy room some might envision."

31) That the Meriden Record-Journal article, cited above, also reported, "Initially, Gaffey planned to pay back hisPAC for the trips with any reimbursement he received from the State, he said, but because of the oversight, hepocketed the extra cash that came in his paycheck."

32) That based on documentation obtained during this investigation it is evident that, between the dates of07/18/2004 and 03/23/2007, Senator Gaffey and Patricia Murphy went on seven trips for which the Senator'sexpenses could be reimbursed by the GAF PAC or the State of Connecticut. Their attendance to one of thosetrips, the inauguration of Christopher Murphy in Washington DC in January 2007. was not a business trip, thuswas not eligible for State reimbursement and none was requested by the Senator, The GAF PAC did, however,pay for $847.62 in expenses for that trip which included airfare, travel agent fees, meals and lodging, Gaffey,accompanied by his children, traveled to Quebec City, Canada, for a three-day Council of State Governmentsconference in August 2007, Although it IS evident that the GAF PAC paid a small amount ($26,37) for sometype of hotel charge, there was no indication that the PAC paid any duplicate reimbursements in addition to the$1,345,88 that was reimbursed to the Senator by the State for that trip.

33) That this investigation has revealed that Senator Gaffey attended a total of six politically-related functionsbetween 07/18/2004 and 03/23/2007 for which he sought duplicate reimbursement for the same expense fromboth the GAF PAC and the State of Connecticut. The double-reimbursements, none of wilich were repaid bythe Senator prior to Kevin Rennie's Harttord Courant article in December 2007, totaled $2,80448, On morethan one documented occasion the Senator contended that it was his intention to pay back his PAC with thefunds that he would eventually receive from the State, but simply forgot to do so,

34) That Amanda Falcone's January 2009 Record-Journal article also reported on Gaffey, "When he realizedwhat had happened over the years, Gaffey said he began to reimburse the PAC until elections enforcement toldhim to hold off on any additional payments until the amount he owed was officially determined, To date, Lubysays, Gaffey has written four personal checks to the committee for an amount totaling a little more than $2,000,At least $500 of that money was not an Issue of dOUble reimbursement, but rather Gaffey paying for PatriciaMurphy's January 2007 trip to Washington, for the swearing-in of U.S, Rep. Christopher S Murphy, Luby said,Gaffey originally billed his PAC for Patricia Murphy's expenses, but after checking with elections enforcementdecided to be consenvative and make the payment out of pocket, Luby said, adding that he believes PatriciaMurphy's trip would have been a legitimate expenditure out of the PAC because she was a volunteer on thefreshman congressman's campaign,"

35) That on May 6, 2009, the State Elections Enforcement Commission approved two negotiated agreementswith Senator Gaffey and his former treasurer, Dennis Ceneviva, Details of the agreements were as follows:

a) Senator Gaffey was fined $6,000.00 which he had to pay from his own, personal funds,b) Mr, Ceneviva was fined $3,000,00 for failure to exercise control as treasurer of the GAF PAC,c) Senator Gaffey was to diSSOlve the GAF PAC and forfeit the remaining funds (apprOXimately $10,000.00 to

PubHc)efore mil on (Date)Jurat

(ThiS IS page 13 of a-,''.l",pa~ge-=,:::A;:':ffi:::d':::V",i!-J'-- T'~!!i]2imaiiJi===;:::?'''/'_---:::;;;~Y.L- _Dale

------A==--_...i!.!4"''#-J'--'lJ''--_.L-..

· - --_~ ~~ ......... ~.~ '.Iv .... ... oJU oJO'OoJ

ARREST WARRANT APPLICATIONJD-CR-64a Rev. '0-1 0C.GS. § 54-221Pr Bk. StlC 36-1, 36-2. 36-3

"~me (I.Mt, FIrs'. Mldelle fnitfltl)

GAFFEY, Thomas P.

Ulv~,,\ t'.l.U.

STATE OF CONNECTiCUTSUPERIOR COURT

'N\oW.f.jlJd, ctgov

Re!.jdence (TowfI) or eccu!sd

Meriden, CTCourt; to be-held ~l (Town)

I Hartford, CTGeogrillphlc;:llNee n'Jmtler 14

Affidavit - Continued$13,000,00 after payment for his legal counsel) to the State of Connecticut

d) Both Gaffey and Ceneviva were to participate in campaign finance seminars in the event that either of themwere to again form a PAC.

The eiection's agency's enforcement director, Joan M, Andrews, said in a statement that the record-keeping ofGaffey's PAC WaS "disastrous" and that the lengthy investigation of the case required a "massive reconstructioneffort," The commission, in a written statement, condemned Gaffey's personal use of the PAC funds as "aserious and grave act," In days subsequent to the agreement, Republicam Party Chairman Chris Healy formallyrequested that the Office of the Chief State's Attorney investigate the matter for possible criminal prosecution

36) That on 07/08/2010 the affiant interviewed Dennis Ceneviva, Senator Gaffey's former treasurer, whoprovided the following information:

a) Whiie he was familiar With the reporting requirements of Candidate Committees, he was not well trained in theadministration of a political action committees. He delegated the bulk of the work to his office staff andbasically trusted Tom Gaffey's JUdgement in how the funds were spent. He had no reason to believe that Mr,Gaffey was misusing the funds in the GAF PAC,

b) Mr, Gaffey's requests for reimbursement were always down to the penny, .. specific amounts for specificexpenditures. This specificity led Ceneviva to believe that Gaffey's accounting pradices were accurate andexpenses were legitimate.

c) Ceneviva assumed that documentation of expenses was being provided to his office staff, but subsequentlylearned that all of the Senators requests were verbal. Seldom, if ever, were any invoices submitted,

d) Mr, Ceneviva was totally unaware that Senator Gaffey was obtaining reimbursement for travel through theState Senate, Had he been aware that reimbursement was being sought through the State, he would nothave authorized travel reimbursement from PAC funds.

e) When the PAC obtained cellular service there were originaliy two telephones, one for Tom Gaffey andanother for David Papandrea who worked for Mr. Gaffey at the senate. Subsequent to some sort ofdisagreement, Papandrea ieft and dropped his cell phone off at Mr. Ceneviva's office. Ceneviva put thephone away and it sat, unused, for quite some time. Ceneviva only became aware that a different cell phonehad been obtained and added to the GAF PAC account after his discussions with Charlie Urso, thus he wasnever aware that Patti Murphy had been given a PAC phone.

l) Ceneviva was asked if he would have been comfortable if Gaffey had explained to him that he wished to beimmediately reimbursed for travel expenses by the PAC and later return the funds after the State issued it'sreimbursement. Ceneviva said that he would not be comfortable with that situation and theoretically wouldhave responded by somehow prorating the expenses, figuring out a logical way for the State and the PAC tosplit the expense, belieVing that it wouldn't be appropriate to request the full amount from both entities,

g) Ceneviva stated that subsequent to the Hartford Courant article by Kevin Rennie, Mr. Gaffey made mentionthat he might have been reimbursed twice for the same travel expenses and submitted several personalchecks to restore some funds to the PAC,

A transcript of the taped interview with Dennis Ceneviva was prepared in the form of a written statementRepeated attempts to schedule a meeting so that Mr. Ceneviva can sign the document have yielded negative(ThiS Is page 14 of a 17 page Affldavli."-) _Dete

Jurat

v ..... Vu, ... v ...... ... v ....... !.n.a \JUU L.JO "-'00"-' v\.. :>.'1 r. 1 • U •

ARREST WARRANT APPLICATIONj()...CR·t,4;j1 R~.. , 10-H)C.G,S. § 54-2aPr Elk. Sec:. 36.-1, 36_2, 36-3


WW'W.jud.cl.go.....

Name (las!, FirsT. Middle Initial)

GAFFEY, Thomas P.Fi:f!5Ioence (Town) of ace:\l,ed

Merldenl CT

Court to be l'Ield ~t (TOWIl)

Hartford, CTGeographicalArea nllm~er 14

Affidavit· Continuedresults.

37) That on 07106/2010 the affiant interviewed Patncia A, Murphy, During the interview Ms. Murphy providedthe following information:

a) She and Tom Gaffey were involved in a personal relationship for several years. While she supported hispolitical efforts, she never actually held any formal position or role with his campaigns or other politicalendeavors.

b) At some point in their relationship Ms. Murphy was considering discontinuing her cellular telephone servicedue to the rising costs to maintain it Mr. Gaffey told her that he wanted her to have a phone and that hewould get her one. Murphy initially declined. but Gaffey told her, "I never go over the minutes. My politicalcalls I charge to my PAC and then I just pay the rest" Murphy accepted the telephone, which she used atwill. until shortly after they ended their relationship at which point Mr. Gaffey had the phone turned offMurphy stated that she was never aware that it was actually a PAC telephone.

c) Murphy recounted the trips on which she accompanied Mr. Gaffey which included NCSL conferences in SanFranCisco, Salt Lake City, Seattle and Nashville, a meeting in Tampa, and two trips to Washington. DC. TheWashington trips were for an education function and Chris Murphy's swearing-in. Murphy was told by Gaffeythat the GAF PAC was paying for Mr. Gaffey's expenses and he was paying for hers.

d) Murphy stated that she was never aware that any of the senator's expenses were reimbursed by the State ofConnecticut until she was told of this by SEEC Investigator Charlie Urso,

e) Ms. Murphy stated that she had an asthma attack during one oftha Washington trips and had to visit ahospital emergency room. This illness, however, occurred after their arrival and well before their departure.The illness caused no change in plans relative to where they were staying and had no effect on the length oftheir stay. Murphy stated that she had not been ill during the Nashville trip.

f) In referencing the same article by Amanda Falcone in which Mr. Gaffey cited Murphy'S illness as the reasonfor their NashVille hotel upgrade, Murphy pointed out that Gaffey had reportedly billed the GAF PAC forMurphy's expenses to attend the swearing-in ceremony for Congressman Christopher Murphy in WashingtonDC. Mr. Thomas Luby. Sen. Gaffey's attorney, apparently told Falcone that, "he believes PatriCia Murphy'strip would have been a legilimate expenditure out of the PAC because she was a volunteer on the freshmancongressman's campaign." Ms. Murphy indicated, "That's just not true, I know Chris Murphy. I gave him afund raiser early on when nobody really knew who he was. But I didn't work on his campaign."

A transcript of the taped interview with Patricia Murphy was prepared in the form of a written statement. Thetranscript was reviewed. signed. notarized and submitted to the affiant.

38) That on 07/14/2010 the affiant interviewed Ms" Deborah Mischler, Paralegal/Office Manager employed byA tty , Dennis Ceneviva. During the interview Ms. Mischler provided the following information:

aT}' Pvblic;)Jurat

a) That she has been employed by Attorney Dennis Ceneviva for over twenty-five years.b) That during the period of time that Mr. Ceneviva was Senator Gaffey's treasurer, calls from the Senator would

typically be answered by her. Bookkeeping and check-writing duties for the GAF PAC fell to her.c) She would receive verbal requests from Senator Gaffey, usually on the telephone" asking that she provide,'Th,s IS page 15 of d 11 fJa~ Affidavit.)

Dtl'le--- .

--~~..r::==-~---.L'-t:P-~!2..-..J~-____=::,~¥__-~~~--L~

ARREST WARRANT APPLICATIONJD-CR-64i1 Rev, 10·10C.G S. § 54-211Pr BIr;. SCI;;. 36--1,36-2, 36·3

Name: (L:l~I. ~Irs'. Mlcdle Inlti(ll)

GAFFEY, Thomas P.

Ulv,')i\. r,l,U.


w-.MN .jud .ct.gov

Ret;idence (Town) of <lctv~"d

I Meriden, CT

tg} Ulb

liou 0 9 al (Town) : GC'o'i1rilphi~;l1

Hartford. CT Ar~a nurt\ber 14

Affidavit - Continuedpayment to him or some other third party for PAC-related expenditures She would write the checks for theamount requested and make notations in the ledger. Documentation for the expenditures was rarely, if ever,provided by the Senator.

d) Mischler was unaware that Gaffey was being reimbursed by the State for expenses that had been paid for bythe PAC. She Was unaware that there was even a mechanism for that process.

e) That Senator Gaffey's aide, Robin Havelin, would frequently cail or visit the Ceneviva office for variousreasons, including PAC and campaign committee finances, Mischler estimates that she would speak withHavelin three to five times per week during campaigns and, when the Senator was gearing up for a PACfundraiser, approximately twice per week.

f) When asked if Robin Havelin was aware that that Mischler was writing checks from the PAC account fortravel, hotels and related expenses she replied, "Oh, yeah,"

g) That on at least one occasion Robin Havelin phoned Mischler relative to PAC funds and stated, "Tom told meto cail you," followed by, "Tom needs you to send oui a check," Mischler could not, however. recall specificdates or PAC payments made.

A transcript of the taped interview With Deborah Mischler was prepared in the form of a written statement. Thetranscript was reviewed, signed, notarized and submitted to the affiant.

39) That on 07/27/2010 the affiant interviewed Robin Havelin, Sen, Gaffey's Legislative Aide. During theinterview Ms, Havelin prOVided the following information:

a) Ms. Havelin, Whose job mainly consists of constituent services, has worked exclusively for Sen. Gaffey fornine and a half years. Havelin also prepares travel authorization, makes reservations and prepares theSenator's claims for travel reimbursement from the Office of Legislative Management

b) After she prepares the reimbursement claims, Sen. Gaffey reviews and signs the claims.c) That it was Sen, Gaffey's standard procedure to have his PAC immediately reimburse him for travel

"xpenses, then pay back the PAC after he received reimbursement by the Stat". Wh"n the affiant askedher. "Do you recall that was the plan?," she replied, "That's typically what our, I am not quite certain for thatparticular event, but that's typically how he handles all that."

d) Havelin stated that subsequent to the published allegations of the Senator receiving duplicatereimbursements for the same expenditures, she and Senator Gaffey had a private conversation during Whichhe explained what had happened, Senator Gaffey told Havelin that it had been hiS intention all along toreimburse the PAC once he received his reimbursement from the State.

e) Havelin said that she truly b"lieves it was an oversight in that Senator Gaffey failed to make thosereimbursements to the PAC, adding that he is a very bUSy man,

f) When asked if she thought it was appropriate for the Senator to submit travel reimbursement claims to theState when he had already been reimbursed by his PAC, Ms. Havelin said that she never knew that he wasbeing reimbursed by the PAC. She stated that she only learned that fact after the story broke in thenewspapers and the Senator told her what his intentions had been.

g) That towards the end of the interview the issue of "plausible deniability" came up. Ms, Havelin stat"d, '''I don'tknow' It's the best thing, it's a great political tactic, too, you know? 'I don't know.'" When the affiant added."Or. I forgol," Havelin laughed and replied, "Exactly"

(This Is page 16 of a 17 pagf! Affld:wlf.)

ARREST WARRANT APPLICATIONJD--eR~40l Rev.1(}..10C,G.S. § 54.23Pro B~. Sec, ~6.1r 35_2, 36~3

Nlltr1a (Last, First, Middle Initial)

GAFFEY, Thomas P.

Affidavit - Continued

UL;)}\ .t'.l.U.


W\.-I.r\"J,/lld,cl.gov

Resid8nr:e (Town) of acclll!lad

Meriden, CTCourl 10 be rJeld at own)

Hartford, CT

LgJ Ul (

G~O~r<lph;c;..1Are~ number 14

A transcript of the taped interview with Robin Havelin was prepared in the form of a written statement.Subsequent to her review of the transcript, Ms. Havelin declined to sign the statement explaining that variouspersonal issues hampered her ability to concentrate on the questions, resulting in what she characterized asseveral vague, disjointed responses, The affiant declined her offer to be interviewed a second time,

WHEREFORE, the affiant states that he has probable cause to believe that Thomas P. Gaffey, the accused, didcommit:

Larceny in the Sixth Degree, in violation of Connecticut General Statute § 53a-119; 53a-125(b), (Dated09/30/2004, described in paragraph # 21 )

Larceny in the Sixth Degree, in violation of Connecticut General Statute § 53a-119; 53a-125(b). (Dated12/07/2005, described in paragraph # 22.)

Larceny in the Sixth Degree, in violation of Connecticut General Statute § 53a-119; 53a-125(b), (Dated10/31/2005, described in paragraph # 23,)

Larceny in the Sixth Degree, in violation of Connecticut General Statute § 53a-119; 53a-125(b), (Dated05/31/2006, described in paragraph # 24.)

Larceny in the Sixth Degree, in violation of Connecticut General Statute § 53a-119; 53a-125(b), (Dated07/20/2007, descrit;>ed in paragraph # 25.)

Larceny in the Sixth Degree, in violation of Connecticut General Statute § 538-119; 53a-125(b) (Dated08/31/2007, described in paragraph # 26.)

---------------------------------------- END -------------------------------------------------

(This is page 17 Df a 17pag~ Affldavlt';

gaffey warrant

Documents