“State of Minnesota County of Hennepin


District Court Fourth Judicial District
U1132 X

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!"" 1 256.98






if more than 6 counts (see attached)

if Domestic Assault as defined by MS 518B01, sub2a,b

State of Minnesota,


Date of Birth 11/23/51


27-CR13-14115 740470 2640492


The Complainant, being duly sworn, makes complaint to the above-named Court and states that there is probable cause to believe that the Defendant committed the following offense(s). The complainant states that the following facts establish PROBABLE CAUSE:

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!"" Your Complainant, Amanda Lange, has been a Criminal Investigator with Hennepin County for 22 years, the past eight years of which have been with the Hennepin County Human Services and Public Health Department (HSPHD) Fraud Investigation Unit. As such, your Complainant has investigated numerous allegations of criminal behavior including the fraudulent receipt of public assistance. I. INITIATION OF INVESTIGATION

In early 2012, Medica Insurance’s Special Fraud Investigations Unit investigated a report that the Defendants, COLIN A. J. CHISHOLM III and his wife ANDREA LYNNE CHISHOLM, were fraudulently receiving Medical Assistance. The State of Minnesota contracts with Medica and other health insurers to provide Medical Assistance to indigent residents of Minnesota. Medica suspected that the Chisholms were fraudulently receiving Medical Assistance, in part, because they reside in a luxury lakeside home in Deephaven, Minnesota and Colin Chisholm portrays himself as a Scottish aristocrat who is a wealthy and successful executive in the broadcasting industry. Medica found that they had paid more than $60,000 in medical claims on the Chisolms’ behalf for services that included massages at The Marsh wellness center and spa in Minnetonka. Medica’s Fraud Investigators referred the Chisholm case to the Hennepin County Fraud Unit for further investigation conducted by your Complainant.


REV. 12/95



HSPHD records show that from 2005 to 2012 the Defendants received $167,420 in Minnesota public assistance benefits. Your Complainant determined that since their initial application for Public Assistance in 2004, the Defendants have made numerous false statements and misrepresentations to the Hennepin County Human Services & Public Health Department. They thereby concealed their assets, income, household composition and their actual residence, including their 28 month absence from Minnesota. As a result, the Defendants fraudulently obtained public assistance funds. Had they been truthful, Colin and Andrea Chisholm would not have been eligible for any of these benefits. The Defendants’ Minnesota Public Assistance fraud includes: Failing to notify HSPHD of their purchase of an 83-foot yacht in Florida for 1.2 Million Dollars. Failing to notify HSPHD that they had moved to Florida where the Chisholms lived for 28 months on board their yacht and later in a home in a seaside community near Palm Beach. Failing to notify HSPHD that they were also receiving Medicaid, Food Stamps and cash welfare assistance from the State of Florida. Failing to report to HSPHD nearly Three Million Dollars ($3,000,000) deposited in bank accounts which they owned, controlled or used to support their lifestyle. Fraudulently concealing that they have lived in luxury lakeside homes in Deephaven, Minnesota since 2008. III. A. DETAILS OF THE CHISHOLMS’ FRAUDULENT SCHEME


The Defendants, Colin A. J. Chisholm III and his wife Andrea Lynne Chisholm, completed their initial Minnesota Health Care Programs Application with the Minnesota Department of Human Services in September 2004, seeking tax-payer funded health care coverage. In December 2004 HSPHD assessed the couple’s eligibility for General Assistance Medical Care. HSPHD requested verification of their income which the Chisholms failed to provide. Therefore, Hennepin County denied their application for General Assistance Medical Care on January 20, 2005. The State of Minnesota, however, approved the Chisholms’ application for MNCare effective January 1, 2005. The State’s approval of MNCare benefits was based upon the false claims in their September 2004 Minnesota Health Care Programs application for health care benefits which the Defendants completed, signed and submitted. B. THE CHISHOLMS’ 2005 PURCHASE OF A 1.2 MILLION DOLLAR 83-FOOT YACHT ON WHICH THEY LIVED IN FLORIDA

Minnesota Public Assistance applicants and recipients are required by law to truthfully disclose their assets. Just weeks after applying in Hennepin County for welfare benefits, Colin Chisholm began negotiating the purchase of an 83 foot “Trumpy” yacht then known as the “Wishing Star.” The Wishing Star was offered for sale by Richard Ross of Ft. Lauderdale for 1.4 million dollars and is described in the attached 2004 sales brochure (See Appendix). In an October 15, 2004 email to Ross, Colin Chisholm stated that his company, TCN Networks had taken “most of (his) available cash up to this date, around $6.2 Million” but that he controlled “about $30 million in Network Television Advertising on CNBC.” In that email, Colin Chisholm stated that he was interested in buying the yacht

Page 3 using “creative financing.” In January 2005, the Defendants and Ross agreed on a purchase price for the yacht of $1.2 million dollars, with a down-payment of $220,000, monthly payments of $7500 and an additional lump sum payment of $157,000 due on March 15, 2005. Defendants took possession of the yacht on January 20, 2005, just three weeks after the couple began to receive MNCare health care coverage. They never reported the yacht to HSPHD. Colin and Andrea Chisholm made payments on their yacht’s mortgage during 2005 totaling $264,375 while they continued to receive Minnesota tax payer funded MNCare health care coverage. C. COLIN AND ANDREA CHISHOLM’S FALSE CLAIMS TO BE MINNESOTA RESIDENTS DURING THE 28 MONTHS THAT THEY LIVED IN FLORIDA

To be eligible to receive MNCare and other public assistance benefits from the State of Minnesota one must reside in Minnesota. If a recipient moves to another state, he or she ceases to be eligible to receive public assistance from Minnesota. Recipients are required to notify HSPHD if they have moved out of state. For 28 months the Defendants lived in Florida while receiving Minnesota Public Assistance. During that time, Colin and Andrea Chisholm were not residents of Minnesota and were ineligible for MNCare health insurance. In their 2004 application for State of Minnesota health care insurance benefits, the Defendants stated that they lived with Andrea Chisholm’s mother, Ruth Lynne Larsen at 3202 Harriet Avenue South in Minneapolis, Hennepin County. However, beginning in January 2005, Andrea and Colin Chisholm lived aboard their yacht which they renamed the Andrea Aras. The Chisholms docked their yacht at a luxury country club and marina at Turnberry Isle, Florida. On December 17, 2005 the Andrea Aras was seized by the U.S. Coast Guard and U.S. Marshals due to lack of payment by Defendants. The Defendants then moved to a house in the seaside community of Lighthouse Point, Florida 30 miles south of Palm Beach while they engaged in a lengthy, costly and failed legal battle in the U.S. District Court and the 11th Circuit Court of Appeals to recover possession of their yacht. Your Complainant reviewed various transcripts and documents pertaining to the U.S. District Court Admiralty case of Ross v. M/Y Andrea Aras, 05-CV-61238-CIV-COHN/SNOW. Defendants’ sworn testimony in this Federal Court case repeatedly contradicts their claims to HSPHD to be Minnesota residents. Instead, both Defendants repeatedly claimed to be residents of Connecticut for the years 2005 and 2006. In March 2006 Colin Chisholm testified: “I currently reside at 15 East Putnam Avenue, Greenwich, Connecticut. That’s my home address. I reside on the yacht Andrea Aras.” (Investigators found that this Putnam Avenue address is a UPS Store). When asked if he lived there during all of 2005, Colin Chisholm testified that “I did live in Connecticut in 2005, yes.” Asked where he and his wife lived prior to January 1, 2005, he testified “We were in New Canaan and, you know, I do not know the address there.” In a September 21, 2006 deposition Colin Chisholm was asked to provide his current address. He responded under oath by saying: “Mailing address is 15 East Putnam Avenue, Greenwich, Connecticut.” He was then asked to state where he actually lived, he testified: “I actually live; interesting statement (sic). Right now, we’re staying at 2521 Northeast 32nd Court, Lighthouse Point, Florida.” Your Complainant’s investigation revealed that in 2004 Defendant Colin Chisholm moved to Minnesota from New Canaan, Connecticut, where he left behind an active felony warrant for larceny. In his decision in the Admiralty suit, U.S. District Court Judge James Cohn wrote: “The Court found Defendant Colin Chisholm’s testimony to be almost entirely lacking in credibility. ...The Court believes that Mr. Chisholm’s testimony was at best evasive, and at worst perjurious…” In Andrea Chisholm’s March 2006 testimony, she was asked to state her current address. “On the Andrea Aras,” she responded. Asked where she lived when not living on their yacht, Andrea Chisholm testified: “2521 32nd

Page 4 Court, Lighthouse Point.” Under further questioning, she agreed that that residence was, in fact, in Florida. When questioned how long she had been living there, Defendant responded: “Since the Andrea Aras was stolen from us.” Asked how long she had resided on their yacht, she responded “Since January.” Asked if she held herself out as a resident of Florida during 2005 when they lived on the Andrea Aras, Defendant testified: “I am a resident of Connecticut, so I don’t live in Florida.” The Defendants never reported to Minnesota authorities that they moved to Florida the same month they began to receive MNCare or that they remained there for 28 months. D. COLIN AND ANDREA CHISHOLM’S SIMULTANEOUS RECEIPT OF WELFARE FROM THE STATE OF FLORIDA

Minnesota Public Assistance recipients are prohibited from simultaneously receiving aid from another state. They are required to report all income, including welfare benefits. After the Defendants failed to return a recertification form their Minnesota MNCare Insurance benefits were suspended from February 1, 2007 through March 31, 2007. On February 1, 2007, Andrea Chisholm gave birth to their son in Palm Beach, Florida. Two days before his birth in Palm Beach, the Defendants claimed to be indigent and successfully applied for welfare from the State of Florida. The Chisholms’ Florida welfare benefits included cash, food support, and medical assistance. In April 2007 they returned to Minnesota and applied for additional Minnesota welfare benefits. Colin and Andrea Chisholm submitted a Combined Application Form (CAF) for full welfare benefits in Hennepin County. The “Applicant/Recipient Needs Assessment” section on the first page of the CAF asked: “Has anyone is the household received public assistance, commodities or food support benefits this month or anytime in the past?” The Chisholms concealed the fact that they were receiving Florida welfare benefits including Medical Assistance, Food Stamps and cash support. Defendants fraudulently continued to receive welfare from Florida after moving back to Minnesota in April 2007. They even renewed their Florida welfare benefits in November 2007, more than seven months after moving back to Minnesota. Their Florida benefits were finally terminated on April 30, 2008. In the meantime, for a year the Chisholms simultaneously received welfare benefits from both states. Andrea Chisholm’s entire pregnancy had been covered by UCare, the Minnesota MNCare provider for her tax payer funded health care. In total, the State of Minnesota paid UCare $22,136.68 in premiums to insure the Defendants’ health care expenses for more than two years while the Defendants lived in Florida E. COLIN AND ANDREA CHISHOLM’S FRAUDULENT RECEIPT OF FULL PUBLIC ASSISTANCE BENEFITS AFTER THEY MOVED BACK TO MINNESOTA

On their April 2007 CAF, the Defendants claimed to have resided at 3202 Harriet Avenue South in Minneapolis since October 2004. Defendants failed to reveal that for 28 months they had lived in Florida. Nor did they report that they had income from Colin Chisholm’s employment or self-employment as Chairman and CEO of TCN Networks and TCN Management, as well as their Florida welfare benefits. Based upon the Chisholms’ fraudulent statements, Hennepin County granted additional welfare benefits to the Defendants through the Diversionary Work Program (DWP) and Supplemental Nutrition Assistance Program (SNAP) a/k/a Food Stamp benefits. The DWP is a “welfare to work” program that most recipients of public assistance in Minnesota are required to complete. The Chisholms’ MNCare health care coverage, originally opened in January 2005, was converted in April 2007 to Medical Assistance due to the birth of their son. And, on August 1, 2007, the Chisholms’ Public Assistance grant converted to Minnesota Family Investment Program (MFIP).



Between April 16, 2007, and March 23, 2012, Colin and Andrea Chisholm completed, signed and submitted to HSPHD 13 forms required for continued receipt of benefits. All of the grants of Minnesota Public Assistance to the Defendants were predicated on fraudulent claims made by Colin and Andrea Chisholm concerning their residency, household composition, household income and available assets. F. COLIN AND ANDREA CHISHOLM’S FALSE STATEMENTS REGARDING WITH WHOM THEY LIVED IN MINNESOTA

Minnesota Public Assistance recipients are required to truthfully report where they live and with whom they live to maintain their eligibility for welfare benefits. This is required so that HSPHD can determine if members of their household have assets and income that disqualify the recipient from receiving welfare. These written statements are made under penalty of perjury. On at least 13 applications, re-certifications and Shelter Verification forms after they moved back to Minnesota, the Defendants falsely reported to HSPHD that they continued to reside with Andrea Chisholm’s mother in her south Minneapolis home. They also falsely claimed to be paying her mother between $300 and $500 per month in rent. Beginning in March, 2008, Defendants moved into a rented luxury lakeside home in Deephaven, Hennepin County with Andrea’s grandparents, Eloise and Francis Heidecker. Mr. Heidecker died on February 6, 2009, at the age of 94. His obituary stated: “In 2006, the Heideckers moved from Estherville to Deephaven, Minnesota. They resided on Lake Minnetonka, at the home of Eloise’s granddaughter, Andrea and her husband Colin Chisholm and their son, Colin.” Following her husband’s death, Eloise Heidecker continued to reside with Defendants in Deephaven. When the Chisholms and Mrs. Heidecker were evicted in September 2009, they moved to another luxury home in Deephaven on the shores of Lake Minnetonka. The CAF provides specific instructions to each applicant, reminding them that they must “List all of the people living in your home even if you are not applying for them and/or the person is not asking for assistance. Program rules require some people to get benefits together.” This statement is found on the top of the page used to list household members. In 2008, 2009, 2010, 2011 and into 2012, the Defendants repeatedly concealed the fact that Andrea Chisholm’s elderly grandmother, Eloise Heidecker, was a household member. They were thereby able to conceal Mrs. Heidecker’s income and her bank accounts which contained several hundred thousand dollars. Andrea Chisholm has exercised a Power of Attorney for her elderly grandmother since at least 2009. As such, she had the ability to manipulate her grandmother’s financial resources, including concealing assets from HSPHD. The eviction proceeding against the Defendants and Eloise Heidecker was delayed because the lease’s signatory, Mrs. Heidecker, suffered from dementia. Colin Chisholm later presented the court with a power of attorney (POA) form from Mrs. Heidecker. That POA gave Andrea Chisholm and her mother, Ruth Lynne Larson, authority to act on Mrs. Heidecker’s behalf. In September 2009, the Defendants and Mrs. Heidecker next moved into a luxury lakeshore home at 3530 Northome Road in Deephaven. The Defendants and Mrs. Heidecker continue to reside there. Colin Chisholm made a verbal rental agreement with the property owner there to pay rent in the amount of $2750.00 a month, which he pays in cash. The Chisholms failed to report either of their Deephaven residences to HSPHD. On every HSPHD form which they submitted, the Chisholms claimed to be living with Ruth Lynn Larson in south Minneapolis.



Minnesota public assistance recipients are required to report their available assets so that HSPHD can determine whether those funds require a reduction or termination of their eligibility for welfare benefits. Bank records and Colin Chisholm’s testimony in the Admiralty case establish that from January 2005 through April 2012, approximately $ 2,630,000 was deposited into accounts which the Defendants owned, controlled, managed or had the use of. The Defendants never reported these assets to HSPHD despite filling out more than a dozen forms requiring such disclosure under penalty of perjury. Just as the Chisholms concealed their income received from their Florida welfare benefits, they failed to disclose the substantial bank accounts and assets which they controlled, as well as the large amounts of money generated by Colin Chisholm’s self-employment as CEO of TCN Inc., which helped fund the Defendants’ lavish lifestyle. On their April 2007 CAF, Defendants falsely reported that they had just $80 in cash, owned no financial accounts, owned no vehicles, were neither employed nor self-employed, and were without expectation of income. The Defendants reported none of the bank accounts which they owned, controlled, or had the use of. These included accounts at TCF National Bank and Associated Bank containing 1) funds from individuals who purchased shares of TCN Networks, 2) income from the sale of championship purebred puppies through Strathglass Kennels, and 3) the Social Security payments intended for Eloise Heidecker. TCF ACCOUNTS: TCF Account #XXXXX1673 Colin Chisholm 6/16/2009 – 11/6/2009 Authorized signer: Colin Chisholm TCF Account #XXXXX6859 Andrea Chisholm 6/19/2009 – 9/8/2010 Authorized signer: Andrea Chisholm TCF Account #XXXXX1683 TCN Networks, Inc. 6/19/2009 – 11/30/2010 Authorized signer: Colin Chisholm, CEO TCF Account #XXXXX8594 TCN Networks, Inc. 4/26/2010 – 1/31/2011 Authorized signer: Colin Chisholm, President CEO Second signer on account: Benjamin Oehler, CFO ASSOCIATED BANK ACCOUNTS: Associated Bank Account #XXXXX6276 Eloise Heidecker 6/30/09 – active Deposits: Authorized signer: Andrea L. Chisholm Depositor’s Signature: Eloise Heidecker (signed by Andrea Chisholm) Associated Bank Account #XXXXX7382 Eloise Heidecker 1/9/2012 – active Authorized signer: Andrea L. Chisholm Depositor’s Signature: Andrea L. Chisholm POA Deposits $ 170,787.65 Deposits: $ 804.58





$ 123,988.03






None of these accounts or assets were ever disclosed to HSPHD.

Page 7 In addition, Colin Chisholm’s testimony in a March 2006 deposition indicates that he had a substantial Bank of America account in Florida. He testified that that on April 14, 2005 he had given the yacht’s seller, Richard Ross, a certified Bank of America check for $100,000. The following exchange occurred between Mr. Ross’s attorney and Colin Chisholm: Q Where did you get the $100,000? A. “It was money, my money” Q. Where did it come from? A. “The Bank of America” Q. Did you have it March 14th? A. “March 14th, I did not, no.” Q. Where did it come from between March 14th and April 14th? A. “Well, let me see if I can remember.” Q. $100,000 comes into your account and you have no idea where it came from? A. “No sir. Not that specific $100,000.” Q. Was there a lot of hundred thousand dollars coming in? A. “I wish.” Q. That’s why it’s kind of odd, isn’t it?...Do you find it odd that you would have $100,000 in your account and you have no idea where it came from? A. “I do not find it odd.” H. COLIN AND ANDREA CHISHOLM’S FRAUDULENT CONCEALMENT OF INCOME

The Chisholms also failed to disclose large amounts of money generated by Colin Chisholm’s self-employment as CEO of TCN Network, Inc. which helped to fund their lavish lifestyle. Colin Chisholm’s 2012 autobiographical note on the business executives networking website “All Cities” stated: “Colin A. J. Chisholm III, XII of Struy is Chairman of the Board of Directors, President and chief Executive Officer at Chisholm Brothers Publishers, Inc., TCN Network, Inc., First Edinburgh Financial LLC, Strathglass Kennel LLC, and a Trustee of The Chisholm Foundation… “TCN Networks, Inc., with headquarters in Miami, Florida, was built to launch satellite-delivered digital Television Network Broadcasting, high-speed internet access and other broadband communications products to the 40 countries of the Caribbean/Latin American region. The Caribbean Television Network is wholly owned by TCN provides up to the minute news, information and sports programming from top network sources in the United States, Canada, Europe, Asia and South America. The Caribbean Music Channel delivers 24-hour accessibility to popular genres of hosted Caribbean music videos and related content. CaribNet.Net, an Internet Services Company, makes available a high-speed internet access service to its hotel, cruise ship and local cable systems affiliates CaribTel, FCC214 Licensed Independent Carrier, maintains a facilities-based state-of-the-art network platform connecting the Caribbean and Latin America with the entire world backbone. CaribTel is a low-cost, high-quality international voice, data and internet access service company. Its clients are first, second, and third-tier carriers and small and medium sized businesses in key markets that involves International Exchange Carrier Services for Termination, origination of voice, International Operator Services and International Director Services.”

Page 8 In his September 21, 2006 Federal Court deposition, Colin Chisholm testified that in the past five months he had added approximately 28 to 30 “shareholders” to TCN Networks, Inc. He was only able to recall five of these people and the amounts of money they had paid him: • Mike Lang • George Case • John Kelly • Charles Frost • Tom Madden TOTAL $ 855,000.00 $ 250,000.00 $ 89,000.00 $ 55,000.00 $ 5,000.00 $1,254,000.00

Asked when these “shares” were issued, Chisholm testified: “[m]ost of them since June of this year, 2006.” When asked to provide an approximation of the gross dollar amount generated by the sale of these shares, Colin Chisholm testified: “Million dollars.” These funds and assets were never disclosed to HSPHD. On their various Combined Application Forms and other required HSPHD disclosure forms, the Chisholms reported that they had no income from employment or self-employment, and owned no stocks, vehicles, bank accounts or assets. By contrast, to potential TCN investors, the Defendants claimed to have assets totaling $97,366,926.27. In the Defendant’s “PERSONAL FINANCIAL STATEMENT Prepared for Colin A.J. Chisholm, XI of Struy and Lady Andrea L. Chisholm On September 15 2009,” they list a TCF checking account with a balance of $12,000.00. Neither this account nor the $97,366,926.27 in assets were disclosed to HSPHD. Andrea and Colin Chisholm also generated income from the sale of pedigree puppies through their business, Strathglass Kennels. Andrea Chisholm breeds and sells championship, show quality, Cavalier King Charles Spaniels. One of Andrea Chisholm’s dogs competed and won an award at the Westminster dog show in 2009. Strathglass Kennels also engages in the business of boarding dogs. None of the funds generated by Chisholms’ selfemployment with Strathglass Kennels has ever been reported to HSPHD. An examination of Eloise Heidecker’s accounts reveals that Defendants were funneling money from TCN as well as Strathglass Kennels through Mrs. Heidecker’s account. After the account was opened in June of 2009, the primary deposits consisted of Mrs. Heidecker’s social security benefits checks. Eighteen months later, significant deposits of TCN investor checks, payable to Andrea Chisholm with memo notations “TCN Stock,” and deposits from Strathglass Kennels LLC, were made into the Heidecker accounts. During that time period, expenditures made from that account also increased and included transactions that would not be expected for an elderly woman with an Alzheimer’s diagnosis. For example, in one month alone, expenditures from Mrs. Heidecker’s accounts included $23,000 in airfare, hotel charges from New York, California and Florida, cell phone bill payments, and fine dining. Not only did Defendants fail to report to HSPHD that Eloise Heidecker was a member of their household, they failed to report the money being deposited into her account from social security benefits, Strathglass Kennels and TCN investors. As such, they concealed from HSPHD money that helped fund their lavish lifestyle and made them ineligible to receive public assistance. J. TERMINATION OF THE CHISHOLMS’ MINNESOTA WELFARE BENEFITS

On December 9, 2011, the HSPHD Fraud Unit followed up on a report that Colin Chisholm was employed as CEO of two companies: TCN Networks and First Edinburg Financial. HSPHD directed that the Chisholms, as public assistance recipients, provide complete copies of their 2010 tax returns and any paperwork regarding the sale or transfer of TCN Network. On January 3, 2012, HSPHD made a second request to the Chisholms, asking for the past three years of personal and corporate tax filings, incorporation documents for TCN and information on any other business associations. Colin Chisholm responded to these requests with a letter stating that, “we have only filed extension for the last 3 years, until I go back to work. Then we would file that I have a paycheck coming in and we would do an amended filing for the entire period. So therefore we never did file as yet. As to TCN – that company did not get funded

Page 9 and never filed anything.” (emphasis added) On March 27, 2012, he wrote on a HSPHD form that TCN Networks, “went out of business in 2006.” On March 30, 2012, HSPHD sent the Chisholms a notice terminating their MFIP and SNAP welfare benefits, effective April 1, 2012, because they failed to explain how they were able to “pay rent and personal expenses with no income.” The Chisholm’s Medical Assistance was terminated May 1st with coverage ending May 31, 2012. Between January 1, 2005 and May 2012 the Defendants fraudulently received public assistance from the State of Minnesota including: $ 22,136.68 89,684.62 52,546.00 1,785.00 1,268.00 $ 167,420.30 Health Insurance Premiums Paid to UCare Health Insurance Premiums Paid to Medica Minnesota Family Investment Program Diversionary Work Program Food Stamps Total

Pursuant to Minn. Stat. §244.10, the State of Minnesota will move the Court to Dispositionally Depart from the presumptive guideline sentence based upon the fact that the offense is a Major Economic Offense under the Minnesota Sentencing Guidelines. The State hereby requests a warrant for the arrest of Defendant COLIN A. J. CHISHOLM III. Investigators have learned that Defendant Colin Chisholm cashed a check and obtained $120,000 in one hundred dollar bills in September of 2013. According to known individuals who reside in Minnesota, Defendant Colin Chisholm is believed to have left the State of Minnesota.

CCT SECTION/Subdivision M.O.C. GOC


OFFENSE COUNT 1: WRONGFULLY OBTAINING PUBLIC ASSISTANCE OVER $35,000 (FELONY) MINN. STAT. § 256.98, SUBD. 1(1); § 393.07, SUBD. 10(c)(1); § 609.52, SUBD. 3; 609.05 PENALTY: 0-20 YEARS AND/OR $100,000

That between January 1, 2005 and May 31, 2012, in Hennepin County, Minnesota, COLIN A. J. CHISHOLM III, acting alone or intentionally aiding, advising or conspiring with ANDREA LYNNE CHISHOLM, obtained public assistance to wit: MNCare, Medical Assistance, DWP, MFIP, and/or SNAP food stamps benefits to which they were not entitled, of an aggregate value of more than $35,000, from Hennepin County and/or the State of Minnesota, through the Hennepin County Human Services & Public Health Department, which public assistance was obtained by means of willfully false statements or representations or intentional concealment of a material facts.

NOTICE: You must appear for every court hearing on this charge. A failure to appear for court on this charge is a criminal offense and may be punished as provided in Minn. Stat. § 609.49. THEREFORE, Complainant requests that said Defendant, subject to bail or conditions of release be: 1) arrested or that other lawful steps be taken to obtain defendant’s appearance in court; or 2) detained, if already in custody, pending further proceedings; and that said Defendant otherwise be dealt with according to law.

Amanda Lange
DATE: Being duly authorized to prosecute the offense(s) charged, I hereby approve this Complaint. PROSECUTING ATTORNEY’S SIGNATURE:



JOHN HALLA (24269X) Assistant County Attorney

C2000 Government Center, Minneapolis, MN 55487 Telephone: 612-348-6557

Court Case # ________________________ This COMPLAINT was subscribed and sworn to before the undersigned this ____ day of __________________, 20___. NAME: SIGNATURE: TITLE:


From the above sworn facts, and any supporting affidavits or supplemental sworn testimony, I, the Issuing Officer, have determined that probable cause exists to support, subject to bail or conditions of release where applicable, Defendant(s) arrest or other lawful steps be taken to obtain Defendant(s) appearance in Court, or his detention, if already in custody, pending further proceedings. The Defendant(s) is/are thereof charged with the above-stated offense.

THEREFORE YOU, THE ABOVE-NAMED DEFENDANT(S), ARE HEREBY SUMMONED to appear on the _______ day of ____________________, 20_____ at _______ AM/PM before the above-named court at _______________________________________ _________________________________________________ to answer this complaint. IF YOU FAIL TO APPEAR in response to this SUMMONS, a WARRANT FOR YOUR ARREST shall be issued.

To the sheriff of the above-named county; or other person authorized to execute this WARRANT; I hereby order, in the name of the State of Minnesota, that the above-named Defendant(s) be apprehended and arrested without delay and brought promptly before the above-named Court (if in session, and if not, before a Judge or Judicial Officer of such Court without unnecessary delay, and in any event not later than 36 hours after the arrest or as soon thereafter as such Judge or Judicial Officer is available) to be dealt with according to law.

Since the above-named Defendant(s) is already in custody; I hereby order, subject to bail or conditions of release, that the abovenamed Defendant(s) continue to be detained pending further proceedings. Bail: $150,000 Conditions of Release: Surrender Passport This COMPLAINTWARRANT duly subscribed and sworn to, is issued by the undersigned Judicial Officer this ____ day of _____________________________, 20____.

!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!!"" NAME: SIGNATURE TITLE: JUDGE OF DISTRICT COURT

Sworn testimony has been given before the Judicial Officer by the following witnesses: STATE OF MINNESOTA COUNTY OF HENNEPIN Clerk's Signature or File Stamp:


RETURN OF SERVICE I hereby Certify and Return that I have served a copy of this COMPLAINT – SUMMONS, WARRANT, ORDER OF DETENTION upon Defendant(s) herein-named. Signature of Authorized Service Agent: