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Thursday, September 29, 2011

15th Judicial Circuit State Attorney

c/o State Attorney Dave Aaronberg
Assistant State Attorney Paul Zacks
Chief Inspector Mike Waites
401 North Dixie Highway
West Palm Beach, Florida 33401
Timothy "Chaz" Stevens
PO Box 1123
Deerfield Beach, FL 33443
Dear Sir:
At the Dec. 12, 2012 City of South Bay Commission meeting, City Manager Corey
Alston falsified the public record by submitting payroll leave accrual documentation
that contained intentionally erroneous information.
In support of this allegation, the following is from Alstons Probable Cause Affidavit:
1. Information Systems Administrator Olivia Mejia mistakenly carried over all
of Alston's unused vacation hours from each year of his employment,
instead of only carrying over five (5) days as allowed by the city
handbook. Based on Alston's contract and Employee Handbook, the
maximum amount of vacation days Alston could have accrued in 2012
was 200 hrs.
2. Mejia, after notifying Finance Director Massih Saadatmand of the over
payment, was told, "We need to justify this."
3. Saadatmand was unable to reconcile 498 hours. He also admitted to
ignoring the mistake and taking steps to cover up the over payment.
4. Alston believes his vacation accrual and carry over are open to
interpretation. I believe Alston smokes some really good shit, mon.
5. According to Human Resource Manager Vicenta Del Bosquez, more
often lately, Allen is not in the office when time cards are due and
therefore she completes his time card for him.
6. Del Bosquez confirmed that many of Alston's actions related to his pay
out of vacation time, use of personal/sick time, as well as the recent
termination of two employees were not done in accordance with the
handbook and/or his contract.
7. City Attorney Thomas Montgomery stated, The payout of vacation time
Alston took was not permissible. It was illegal for Alston to initiate and
process his own payout because in the first place Alston was not
permitted to do so per his contract and City Handbook.
Finally, Alston drafted, and then presented, Resolution 09-2013, Ratifying recent
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compensation to the City Manager, an employee of the City Commission of the City of
South Bay. That document intentionally contained false information. Therefore, I allege
Corey Alston violated Florida law by falsifying the public record.
Therefore, I respectfully request the Palm Beach State Attorneys Office hold Alston
accountable for this action.
Happy hunting;

Timothy Chaz Stevens
Enclosure (1)
OBTS Number
3. for Wlll'rllnl
[71 2. N.T.A. 4. for Capia
w 1 AgenC:y URI Number
I Agency Name IIOgency t18pOr1 Number (N.T.A. 1 onty)
FL050015A Palm Beach County State Attorney's Office
I :'!r Type:
R 1 Felony R 3. M-meanor
B 5.
If Weapon Seized
I Multiple :;; C as many
z as ..,ply. 2. Traffic Felony 4. Traffic Mi-.neanor 6. Other
Enter Type

Location of Arrest (Including Name of Buaonees)
Location of Off.,.. (Buainesa Nama, Addraes)
335 SW 2 Ave, South Bay, Fl. 33493
Date of arrest
I Time of Arr8S1
I Booking Date I Booking Time I Jail Date I Jail Time I Location of Vehicle
Name (Last. First. Middle)
Alias (Name, OOB, Soc. Sec. I, Etc.)
Alston, Corey Lamont
Date of Birth
I Height
1. W.;ght
II Eye Color rairCofor II Complexion
I Amencan lndoan I B M
B Black 0- OroentaVAsian
09/26/1977 6'00" 200 Brown Black Dark MED
Scars, Marks. Tatoos, Unique Phyaical Features (Location. Type, Oescnption)
Marotal Status

lndiclllion of:

Influence (J
!z Local Address (Strelll, Apt. Number) (City) (Slate) (Zip) Phone
I rype: 3. Florida
( )
I 3
2. County 4. Out of State

Permanent Address (Strest, Apt Number) (City) (State) (Zip) Phone
Address Source
8260 NW 48th Street Lauderhill FL 33351
( ) Known Q
Business Address (Name. Street) {City) {State) {Zip) Phone Occupat.,
City of South Bay, 335 SW 2 AVE, South Bay FL 33493
{ 561 >r996-6751
City Manager
0/L Number. State
I Soc. Sec. Number I INS Number I Place of Birth (City, State)
A423-112-77-346-0 (Florida) 263-81-6710
Ft. Lauderdale, Florida
Name (Last, First. Middle) Race Sex Date of Birth
H 1. Arr8111ed Q 3. Felony

2. AI Large 4.Mi8demaanor
n 5. Juvenile
Co-Oef-nt Namt1 (Last, First, Middle) Race Sex Date of Birth H ,_ Arr8111ed

2. At Large
5. Juvenile
B Parent
Name (Last) (First) (Middle)
Residence Phone
Legal Custodian
( ) Olher:
Address (Street. Apt. Number) (City) (State) (Zip) Busineu Phone
( )
Notified by: (Name)
1 Date I Time
Dept. and Rei- 3. Incarcerated

Released To: (Name) Relalionship
I Date
The above address detr,;:dant and I en;) parents. The child and I or parent was told School Attended Gr8de
['Jkeep the Juvenile rt Clerks ce ( hone 355-2526) tnfor of any change of addraes.
Yes. by: (Name) [ No: (Reason)
IIJtiiiCriptoon or Property Value 01 Property

R. Smuggle K. Dispense/ M. Manufacture/ Z. Other

B. Barbiturale H. Hallucinogen P. t;_araphetnaliel U.Unknown
D. Oeto- Distnbute Produce/ C. Cocaine
P. Poeseas T. TraffiC E. Usa Cultr.ate A. A'mi>t>etamone E. Heroin
Charge Description
I Counts I Domeauc
Statute Violatoon Number
I Violation of ORO 1
Grand Theft 1 mntl'N
Drug Activity,IOrug Type I Amount I
Warrant/ Capias Number
N N $25,139.00 2012PI000111 A99
Charge Description
I Counts IDomeatfc
Statute Violation Number
I Violation of ORO ,
Cl []Y []N
I Offensa 1
Drug Actovit1 Drug Type I Amount/ Unit
Warrant I Capias Number
Charge Oescroption
I Counts I Oomeallc
Statute Violation Number
I Violation of ORO I
Drug Actovityl Drug Type lAmount I Unit
Warrant I Capias Number
I Bond
Charge Oescriptoon
I Counts I Domeatlc
Stlllute Violatoon Number
I Violation ot ORO '
w VIolence
[IY []N
Drug Actovityl Drug Type I Amount/ Unit
Warrant I Capoas Number
I Bond
[ J lnstructoon No. 1 Location (Court. Room Number, Address)
rr: I.J Mandatory Appearance on Court
lnstructoon No. 2
Court Date and Time
IL You need not appear on Court but must
comply woth instructoons on Reverse Side.
Month Day Year Tme A.M. P.M.

Sognature of Defendant (oo Juvenile and Parent/ Custodoan) Dille Sogned
HOLD for other Agency

Name Verification (Printed by Arrestee)
H Dangerous d R8SISI8d Arrest
Name of Arrestong Offocer
1.0. , (PRINT)
Q lJ Suocodal Other:
"' Intake Deputy 1.0. I I Pouch I
Transportong Ollocer 1.0., Agency
1 1
Witness here of SOJbfecl sogned woth an "X"
I PROBABLE CAUSE AFFIDAVIT !Arrest 3 Request for Warrant
Juvenile I
2 NTA 4 Request for Capias
Agency ORI Number
I Agency Name I Agency Report Number
FL 050015A
Office of the State Attorney
SA - 2012PI000111A99
15th Judicial District
Charge Type
X 1 Felony c 3 Misdemeanor c 5 Ordinance I Special Notes
Check all that
Apply c 2 Traffic Felony c 4 Traffic Misdemeanor c 6 Other
Name (Last, First, Middle) Alias
l RaB
1 09,26,1977 Alston Corey Lamont M
Charge Description Charge Description
Grand Theft
Charge Description Charge Description
VIctim's Name (Last, First, Middle)
I Race
I Date of Birth
City of South Bay
Local Address (street, Apt (City) (state) (Zip) Phone Address Source
335 SW 2"d Avenue South Bay FL 33493 (561 )996-6751 Known
Business Address (Name, Street) (City) (Slate) (Zip) Phone Occupation
Same as Local Same City Government
The undersigned certifies and swears that he/she has just and reasonable grounds to believe, and does believe that the above named Defendant committed the following violation of law.
The Person taken into custody .
[] Committed the below acts in my presence. [] Was obseiVed by Who told That he/she saw the arrested person commit the below acts.
c Confessed to
Admitting the below
X Was found to have committed the below acts, resulting from my (described) investigation.
On The 30 Dayot October 211 12 AI 1000
The State Attorney's Office Public Integrity Unit received information from City of South Bay employee George Sandiford
about recent questionable behavior of the City of South Bay City Manager Corey Alston. Sandiford advised Alston obtained a payout
of his vacation leave for over $25,000.00 in August 2012, while remaining employed by the city. Sandiford suggested the payout was
obtained via a verbal approval by three (3) of the five (5) City Commissioners, outside of a public Commission meeting, prior to the
payout and that the hours Alston was paid for were in excess of hours actually accrued.
Between Monday November 12th, 2012 through Tuesday November 27th, 2012 South Bay commissioner Wilson, Vice
Mayor Johnson, and Mayor Walker-Turner all provided sworn statements that were consistent with each other. In summary each
advised they were contacted by Alston in regards to their consent for him to receive a payout of his vacation leave hours. Each person
told Alston that if he obtained a majority vote, they would also vote ''yes" to the payout.
Alston did not mention the specifics of the payout, only that he wanted a payout. Sworn statements were also taken from
Commissioners Berry and Kyles. Both advised they were never contacted by Alston regarding his payout and they only learned of the
payout after the payout was made.
On Wednesday November 14th, 2012 Detective Flechaus and I met with city clerk Jessica Figueroa. In meeting with
Figueroa, we obtained Alston's 2012 contract with the City of South Bay, Florida, City of South Bay's Handbook, and other
documents. In reference to vacation and sick leave benefits by Alston, his contract states the following.
VI. Benefits:
Vacation leave- Mr. Alston shall be granted 20 vacation days per year. All provisions of the employee handbook shall govern
vacation days.
Sick leave- Mr. Alston shall be granted 20 days sick leave per year. All provisions of the employee handbook shall govern vacation
The City of South Bay Handbook section VII under Employee Benefits states the following in the first paragraph (verbatim):
"Because your time of rest and relaxation is important to the City of South Bay, a carry- over of no more than fzve vacation days per
year is permitted".
Therefore, based on Alston's contract and the City of South Bay's Employee Handbook the maximum amount of vacation days
Alston could have accrued in 2012 was 25 vacation days or 200hrs (20 days granted that year in May per his contract and 5 days
carried over from the prior year as per the handbook). As also stated in the handbook, "Pay in lieu of time off may be received if
warranted by work load requirements and approved by the City Manager''. Note that it does not provide for personal reasons.
Furthermore, the last paragraph in the Employee Benefits section states: "Only employees who resign from their employment in good
standing, and whose resignations are accepted by the City, are paid unused vacation pay at the time of departure" (emphasis added).
Note that Alston did not depart from the City and he is still employed. Note that five (5) vacation days equals 40hrs.
On Wednesday November 14th, 2012 in a sworn statement Figueroa advised she became aware of Alston's payout for
vacation time approximately two (2) months after Alston actually received the funds. The payout came to her attention when a city
commissioner made a request to her office for records related to the payout. advised that the payout appeared to be
processed by Alston without the approval of the commission; due to the fact that she was not aware of any resolution being presented
to the commission. Figueroa explained she is responsible for preparing resolutions for presentation to the commission and in the case
of the payout she was not notified.
On Tuesday November 20th, 2012, members of the Public Integrity Unit attended the City of South Bay City Commission
Meeting. In attendance were Mayor Shirley Walker-Turner, Vice Mayor Linda Johnson, Commissioner Joe Kyles, Commissioner
Esther Berry, Commissioner John Wilson, City Attorney Thomas Montgomery, City Clerk Jessica Figueroa, Human Resource
Director Vicenta Del Bosquez, Finance Director Massih Saadatmand, and City Manager Corey Alston. During the meeting,
"resolution 09-2013, Ratifying recent compensation to the City Manager, an employee of the City Commission of the City of South
Bay," was discussed. Commission members questioned the specific number of hours, four hundred ninety-eight (498) in which
Alston received payment for, and how it was possible for him to accrue such a large number of hours. Alston responded to these
questions by saying he did not believe he was paid for that number of hours and requested documentation from the Finance Director
to show the exact number of hours paid out. Commission members moved on to discuss other issues and during that time
Saadatmand returned with documentation of Alston's payout. Commission members returned to the issue of the payout later in the
meeting, however, they never requested information from the document provided to Alston from Saadatmand and ultimately voted to
approve the resolution. The commission members who were contacted in advance of the payout by Alston acknowledged their former
discussions and stated the conversations took place outside of a public meeting.
On Tuesday November 27th 2012, City of South Bay's Accounting Specialist III/ Information Systems Administrator Claudia
Cano provided a sworn, recorded statement. Cano advised she was assigned to the Finance Department when Alston received the
payout of his accrued vacation hours and said Saadatmand was her immediate supervisor. Cano said although she was in the office on
the day of the requested payout she was not asked or to assist Saadatmand in processing the payout. Cano learned about the payout the
same day after the close of business when she was contacted by Olivia Mejia who was on vacation. After becoming aware of the
payout, Cano said she checked Alston's contract and the contract noted that Alston could not get a pay out of leave time unless he
separated from the City. Cano said according to her review of Alston's contract he is awarded one hundred sixty (160) hours per year
each May and per the City Handbook Alston could only carry over forty ( 40) hours per year. Since this amount adds up to a
maximum accrual of 200 hours and Alston was paid for four hundred ninety-eight (498) hours, Cano requested that Saadatmand
review the hours paid out to Alston and contact the city attorney to discuss the accrued hours to make sure they were correct. Cano
said she was present when Mejia told Saadatmand that she had erroneously calculated Alston's vacation accrual. Cano advised
Saadatmand said he would "review it." Cano said to her knowledge Saadatmand has done nothing up to this date to correct the
problem or to notify the commission members of the error.
On Tuesday November 27th, 2012 Olivia Mejia, assistant to the Finance Director Massih Saadatmand's provided a sworn
statement that advised on Tuesday, August 7th, 2012 she was on vacation leave. Mejia said she received a call outside of normal
business hours from Saadatmand who requested her password to access the payroll system so he could process the payout. Mejia said
she thought this was suspicious because Saadatmand was doing this work himself, because it was outside of normal business hours
and because payroll does not usually get processed until the next day (Wednesdays). Mejia said, to her knowledge, a payout such as
this was not done unless an employee was separating from the City. Mejia said she questioned Saadatmand about doing the payout in
such fashion and Saadatmand told Mejia to keep this "confidential" and not to tell anyone else.
Mejia said that subsequent to the payout of Alston, she conducted a review of Alston's contract and the city handbook to
determine how Alston could have accrued such a large number of vacation hours. During this review she realized she had made an
error in calculating Alston's total amount of accrued vacation hours. Specifically, Mejia advised she mistakenly carried over all of
Alston's unused vacation hours from each year of his employment instead of only carrying over five (5) days as allowed by the city
handbook. Mejia immediately notified her supervisor of the error and over payment. Mejia was told by Saadatmand "we need to
justify this". Mejia said that Saadatmand has done nothing, to her knowledge, to correct this overpayment since she made him aware
of it in the beginning ofNovember 2012. Mejia said she has not been directed to make any corrections in the payroll system.
On Wednesday November 28th, South Bay Finance Director Massih Saadatmand provided a sworn, recorded statement.
Saadatmand advised he has been the Finance Director for approximately two (2) years and that he answers directly to Alston. During
his statement Saadatmand was asked to reference Alston's contract and city employee handbook for matters related to accrual of
employee vacation hours. Specifically, he was asked to refer to these documents to reconcile how Alston was able to accrue 498 hours
of vacation leave. Saadatmand was unable to reconcile 498 hours and admitted that the amount of hours was an error. He also
admitted he processed the payout outside the normal course of business and that he told Mejia to keep it confidential. He did this
because he did not want anyone including the commission members to find out about the payout. Saadatmand also admitted he
became aware of the error made by Mejia that resulted in an over payment to Alston; yet he did nothing to rectify the mistake. Instead,
he advised he took steps to cover up the over payment.
On Wednesday November 28th, 2012, Alston provided a sworn recorded statement. Alston was provided with a copy of his
contract, the city handbook, a copy of the action form outlining the payout and a copy of his paystub from the time frame of August
7th, 2012. During the statement Alston was asked to calculate the total number of hours of vacation hours he is awarded each year
according to his contract and the total number of hours he is allowed to carry over each year. Alston continuously advised he is
governed by his contract alone and that the city handbook does not apply to him because he is the City Manager. He also advised that
his vacation accrual and carry over is open to interpretation. It should be noted, his contract specifically notes the number of hours he
is awarded annually and refers to the handbook regarding the carryover of hours. The handbook specifically notes that only five (5)
days of vacation time can be carried over each year. Based on these facts, the maximum amount of vacation hours Alston could have
accrued at any time during the course of his employment is two hundred (200) hours. During his statement, Alston said if we were to
look back at the historical record, there have been many exceptions over time where prior city managers and other employees have
rolled over a substantial amount of time not used by employees. Alston was then asked if the commission had voted on his vacation
payout. Alston stated the city commission, at the most recent meeting November 20th, 2012 did vote to approve his vacation payout
based on the number of hours that rolled over since he has been employed with the city of South Bay. Alston was asked if the
information the city commission was provided with prior to their vote, was provided by him. Alston stated untruthfully "no." Alston
said all of the information came from the fmance department. Alston stated he ''played no role in any way providing information on
any of this" and that he intentionally "stayed away" from providing any information so they could get exactly what they needed.
These statements are in direct conflict with information obtained from both Del Bosquez and Saadatmand, who advised that Alston
prepared his own action form with the number of 498 hours listed as the number of hours to be paid out. When asked to refer to the
action form, Alston admitted that the form was written in his handwriting and was signed by him. He also admitted that he only
received three verbal votes from various commission members and that his payout was never discussed or voted on publicly until after
he received payment and this investigation ensued. It should be noted that Alston generalized his actions regarding this payout and did
not answer direct questions related to the process he followed in order to obtain this payout. Additionally, Alston blamed the finance
department and the human resource department for any errors associated with his payment, despite the fact that he is the person who
initiated the payout and received the benefit.
Alston was then questioned about when his individual conversations with the commissioners occurred and if they were all on
the same day. Alston advised once he began "chatting" with the commissioners, it took several days. Alston stated that after
receiving the approval from the three (3) commissioners, he met in person with the Mayor to re-affirm her permission and she said
"yes." Alston went on to explain how he has verbally polled commissioners and verbal authorization on a number of things in the
past. Alston was asked if during his conversations with the commissioners he had mentioned how much money he was getting with
his payout. Alston advised he did not remember the details of the conversations. Alston stated he believes he was asked by all three
(3) commissioners polled what the amount of his payout would be and he advised them it would be between twenty five (25) and
thirty thousand dollars ($30,000). Alston was then confronted with the fact that each of the commissioners had provided sworn
statements and they were all shocked at the amount of Alston's payout. In response, Alston said again that he did not know the exact
hours he was paid out, he did not believe anything was done wrong and further, he stated if the city commissioners had an issue with
his payout, the number of hours, or the amount, then this would never have happened. Alston was questioned as to why he did not
poll Commissioner Berry and Kyles on the issue of his payout. He advised he attempted to contact Kyles, however he was
unsuccessful. With respect to Berry, he advised he did contact her, but she did not respond. He went on to say that it was likely she
did not respond because she has relayed to him in the past that she believes all business between them should be discussed in public.
On Thursday November 29th, 2012, City of South Bay Human Resource Manager/Executive Assistant Vicenta Del Bosquez,
provided a sworn statement. When questioned about time cards and action forms that would show or calculate time at work, time
taken off and time accrued for both sick and vacation, she said generally employees keep track of their own time and submit their own
time cards, which indicate the amount of time actually worked each week and the amount of time taken off either in the form of
personal/sick or vacation time. When Alston first started his position, he kept his own time card, however, Del Bosquez said more
often lately, he is not in the office when time cards are due and therefore she completes his time card for him. Del Bosquez explained
that this is somewhat of a difficult job due to the fact that Alston does not regularly report his schedule to her. Therefore, if he is not in
the office on a particular day, she just assumes he is conducting city business outside of the office and does not subtract time from
personal or vacation leave accruals. Del Bosquez advised she is familiar with Alston's contract and the city employee's handbook.
She discussed that Alston is allowed twenty (20) days of vacation and sick/personal time each year on his anniversary date and that he
is allowed to carry over five ( 5) vacation days ( 40 hours) at the end of each year, if he has not used those days. Del Bosquez was
asked specifically about the payout of vacation time that Alston received in August of2012 and how she became aware of the payout.
Del Bosquez advised that in April of 2012, she had made a request to Alston to roll over thirty-two (32) hours of her own vacation
time, due to the fact that she was not able to take the time off prior to her annual anniversary date. Del Bosquez advised she has
several duties outside of human resources and that taking time off would hinder city business. Del Bosquez said Alston approved her
request and in August 2012, after referring to the handbook, Del Bosquez requested to be paid for the thirty-two (32) hours. At the
same time, she said Alston mentioned to her that he too was interested in obtaining a cash out of his vacation time. Alston then asked
her how he could find out the amount of accrued time he had and Del Bosquez said she showed him that his most recent paystub
would reflect his time accrued. Del Bosquez said she and Alston looked at his most recent pay stub together and she recalled Alston
commenting that he had a lot of accrued hours. Del Bosquez said upon learning how many hours he had, Alston called the fmance
director Massih Saadatmand and requested that he report to his office. Del Bosquez said she was present with Alston and Saadatmand
when Alston filled out an action form indicating that he was to be paid for four hundred ninety-eight (498) hours at an hourly rate of
fifty dollars and forty-eight cents ($50.48) and hour, for a total of twenty-five thousand, one hundred thirty-nine dollars and zero cents
($25, 139.00). Del Bosquez was not aware of any conversations Alston had with any of the council members regarding approval of
this payout, however; she said that Alston verbally stated that the Mayor had approved the payout. Del Bosquez was asked how;
based on the information in the handbook and in Alston's contract, he could have four hundred ninety-eight (498) hours accrued. Del
Bosquez stated she could not understand how he had so many hours. When questioned about Alston's time taken off from the city,
Del Bosquez said the amount of time reflected in the official records appeared to be inconsistent with the actual amount of time
Alston took off. More specifically, she advised that her recollection was that Alston took off much more time than was actually
reflected in the official documents. Del Bosquez was also asked if she had knowledge of whether or not Alston had taken any
vacation time off following his wedding, which was on or about September 1st, 2012. Del Bosquez said Alston took approximately
one ( 1) week off after his wedding, which was interesting to her because according to what she knew, he had just cashed in all of his
vacation time. She learned that Alston took personal/sick time off following his wedding, which according to handbook is not
allowed. Overall, Del Bosquez confirmed that many of Alston's actions related to his pay out of vacation time, use of personal/sick
time, as well as the recent termination of two employees were not done in accordance with the handbook and/or his contract.
On Thursday November 29th, 2012, City of South Bay Attorney Thomas Montgomery provided a sworn, recorded statement.
Montgomery is the City Attorney for the City of South Bay and has been for the past five (5) years. Montgomery started off by saying
that the payout of vacation time Alston took was not permissible. He advised it would only be considered if Alston was to separate
himself from the city or vice versa. Montgomery said he never knew about the payout until after the fact and he did not see the
resolution until the November 20th, 2012 council meeting because Alston had written his own resolution and put it on the agenda.
Montgomery said that when Alston polled the three (3) council members and they acknowledged the approval prior to a resolution
being written and ratified at a council meeting before the payout he believed that it violated part of the Sunshine Law. Montgomery
said he had advised Alston and the other members of this at the November 20th, 2012 meeting and they went ahead with the vote
anyway. Montgomery said, in his opinion, it makes no legal sense to pay someone (Alston) in advance of money they may not have
earned. Furthermore, the amount of the Alston's payout would require the city to make an amendment to the budget which, to his
knowledge, has not been done. In conclusion, Montgomery said it was illegal for Alston to initiate and process his own payout
because in the first place Alston was not permitted to do so per his contract and City Handbook. Also, the process by which Alston
took with the three council members and not the other two members to get his payout approved violated the Sunshine Law. For
specific details of the interview with Montgomery, please refer to the recording which has been placed into evidence at the SAO.
In summary, Alston is governed by the terms of his contract, which also refers to the city handbook, regarding the earning
and use of vacation and sick hours. Neither of these documents allows any employee to obtain a payout of any type of leave, unless
their employment is terminated. Alston repeatedly advised during his sworn statement, that the contract and handbook were
inconsistent with his interpretation of both. Contents of his sworn statement are in direct conflict with the facts contained in the
contract, the handbook and in the sworn statements of other witnesses in this case.
Due to the above information, there is probable cause to charge Defendant Corey Lamont Alston with Grand Theft because
he knowingly obtained or used, or endeavored to obtain or to use, the property of another with the intent to, either temporarily or
permanently: deprive the other person of a right to the property or a benefit from the property and/or appropriate the property to his
own use or to the use of any person not entitled per F.S.S 812.014(2bl).
The foregoing Instrument was sworn to or affirmed and subscribed before me this
Who is personally known to me and/or produced Identification.
BBPD REV. 0.1.0
WHITE- Court Copy
, Day of '*'
GREEN State Attorney YELLOW- Agency

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