AFFIDAVIT OF PROBABLE CAUSE
Your affiant, Detective Edward P. Nolan, is currently a Detective assigned to the Chester
County Detectives Office in West Chester, Chester County PA. I have been a law
enforcement officer for over thirty-five years with the majority of that time in
investigative units.
The known facts of this case are as follows: In December of 2007, Larry Constable,
owner and operator of LC Auto Body Inc., located at 3608 Leike Road, Parkesburg,
Chester County, PA, reported a theft to the West Sadsbury Police Department. Larry
Constable became aware that an employee of two years, Rhonda S. Hunter, the accused,
had during the course of her employment diverted funds from the corporate account of
LC Auto Body to her own accounts without authority or permission of the owner, Larry
Constable.
Larry Constable was interviewed by your affiant. During the course of the interview Mr.
Constable described the scheme where the accused, Rhonda S. Hunter, who was
employed as the book keeper for LC Auto Body would utilize her position to divert funds
for her own use. Constable described how using a company computer Hunter would
artificially inflate payments to vendors to cover the fact that she was writing checks to
herself. Constable said that after Hunter would submit monthly reports to him she would
go back into the computer and change the amounts paid to vendors to reflect the actual
payments. Constable stated that the excess funds would then be converted into checks in
varying amounts to Rhonda S. Hunter.
Constable stated that he contacted the company's accountant, Larry Davis. Mr. Davis
conducted an audit of the checks drawn on LC Auto Body's Fulton Bank account
between September 2005 and late December 2007. The audit indicated that Rhonda S.
Hunter, a part time employee, initially making $12 an hour was receiving checks far in
excess of what her part time position would normally be compensated for. Some of the
checks made payable to Hunter were drawn from a ledger used for accounts payable.
These checks with a five digit check number would not be used for payroll purposes
according to Larry Davis and Larry Constable. A review of the checks issued to Rhonda
S. Hunter during this time frame shows that on at least thirty-three (33) occasions.
Rhonda S. Hunter drew checks from this ledger in her own name.
On 1-24-2008 Larry Davis, the accountant for LC Auto Body told your affiant that he
discovered that even checks that appeared to be "normal" were compromised by the
accused. He had determined that at some point Hunter gave herself a raise to $14 an hour.
Davis told your affiant that he also discovered that during some pay periods Hunter
would use the base of $14 an hour and then show additional hours being paid at $24 an
hour. Davis indicated that it will take some time to determine the full extent of this
scheme and the total loss to LC Auto Body Inc.
On 1-24-2008 the accused Rhonda S. Hunter was interviewed by your affiant inside
Chester County Detectives. In a post Miranda statement, Rhonda S. Hunter admitted that
she had defrauded LC Auto Body Inc during the course of her employment by making
checks payable to herself that she knew were false. Hunter indicated that she had engaged
in a scheme to take funds from the company since "at least November or December
2006". Hunter stated that she used the money to fuel a illegal drug habit that caused her
to consume between $300 to $800 a week in heroin and crack. Hunter told your affiant
that she would take funds from one ledger and transfer them to another ledger to conceal
her activity.
Rhonda S. Hunter indicated that she had no idea how many checks she had written to
herself. She also indicated that she did not know how much money she had stolen during
the course of her employment. Hunter stated that she knows she had written some checks
for between $3000 and $4000 dollars but that none of the checks were over $5000.
A review of the checks issued by LC Auto Body by your affiant also shows that on at
least three (3) occasions checks were hand written for payment to Rhonda S. Hunter.
Larry Constable informed your affiant that payroll checks would not be hand drawn. He,
Constable, would hand out the paychecks each week.
Your affiants review of the checks from LC Auto Body also shows that on at least fifteen
(15) occasions checks were drawn from the payroll and accounts payable ledgers made
payable to Rhonda S. Hunter in excess of $2000.00
All the checks made payable to Rhonda S. Hunter bore the signature stamp of Larry
Constable. Larry Constable indicated that Rhonda S. Hunter had the authority to use the
stamp for official checks issued by the LC Auto Body, including payroll checks.
Constable told your affiant that Rhonda S. Hunter did not have permission or authority to
use the signature stamp on any checks or documents outside the normal course of her
employment.
Larry Constable stated that after the initial theft was discovered in mid December 2007,
but before a total comprehensive review of the accounts, he confronted Rhonda S. Hunter
about the checks. Constable stated that Hunter admitted to him that she had taken money
due to a drug addiction. She acknowledged at least ten thousand ($10,000.00) in missing
funds but did not believe she had taken in excess of one hundred thousand ($100,000.00)
Your affiant was able to review copies of checks that bore the name of Rhonda S. Hunter
where these checks were deposited into an account bearing her name at the Fulton Bank.
Fulton Bank, which is headquartered in Lancaster County, does business in Chester
County.
The checks and actions that are under investigation were all drawn on the business
account of LC Auto Body Inc which is headquartered at 3608 Leike Road, Parkesburg,
Chester County PA. It is at this location where Rhonda S. Hunter was employed as a part
time book keeper for LC Auto Body Inc.
The total amount of money stolen by Rhonda S. Hunter that can be attributed to her to
date is in excess of $109,000.00. These thefts include the fraudulent issuance and forgery
of more than one hundred checks between September 2005 and late December 2007.
Based on the above information your affiant believes that probable cause exists to charge
Rhonda S. Hunter with the crimes outlined in this complaint.