pe, [COMMONWEALTH OF PENNSYLVANIA (COUNTY OF MONTGOMERY POLICE CRIMINAL COMPLAI NT COMMONWEALTH OF PENNSYLVANIA. vs. IMagistertal District Number: 38-1-07 (NAME and ADORESS) MID) Hon, MICHAEL P. QUINN THFFANY BROKENBOROUGH lAddress: 925 MONTGOMERY AVE Tat he ice Rem nial wr SUITE 300 124 ELM AVE NARBERTH, PA 19072 ARDMORE, PA 19003 [Telephone: (610)896-8585 NGIC Extradition Code Type — a Felony rat TS Felony Pend, CC - Misdemeanor Surounding States obtance D2 -Fetony us, 6-Felony Pend Extraction Determ. E} D- Misdemeanor No Extractor 13 - Felony Surounding Stats] A- Misdemeanor Full 1D E- Misdemeanor Pending 14- Felony No Et, 8- Misdemeanor Umted OF - Misdemeanor Pending Extradition Determ. DEFENDANT IDENTIFICATION INFORMATION GGFa-90/ Tene Cs ES SS GENDER | 003 09/26/1991 | ros. ‘Add. DOB [cope CiMale etme Haim Tat Rane = Female | MA TIARAH BROKENBOROUGH RACE D whe DhaAsian i Black Ci Native American ETHNICITY 5 Hispanic Bo Nontiepanie unknown HAIR COLOR Gren avy Crna edu) CYSDY anay) ET RW Tae) CTE rupley LT Wo Mak sik) Clonovorane) — Chwicamit) Chex inka) Chenu corer) Dawes etn (lense / stew Eve colon Drak isc) Cpa (ey BRO (Brow) 11 GAN (Green) GY Gren [ Drraz race _E1MAR Wareon) Clon ink) MUL (nutelores E008 Antone DNA TIYES BE WO DNA Location ‘werent Ciba _| FOI Number [at amor 120 Datendant Fingerprinted | LIVES BNO WEIGHT in, Fingerprine Gassincation 5 5| DEFENDANT VEHICLE INFORMATION. Sais | FaamaeP—Regisvaton ~~] conn veh Sahoo! py Pah NCTE Veh Cees —tag—| Pate # [= Pe | ecearet ma OTS oP x ar — [Wake oder vie ° ™ jin (" Qo Office of the attomey for the Commonwealth Approved 1 Disapproved because: aa a OETA TiS RT EROS STT i /E EDWAI 1, DETECTIVE EDWARD SARAMA do hereby state: 1, MT accuse the above named defendant who lives at the address set forth above D1 accuse the defendant whose name is unknown to me but who Is desctbed as . 144/41559 E PA04614 OT Sateen encima, Bagasaapge OI accuse the defendant whose name and popular designation sre unknown to me and whom Thave therefore designated as John Doe or Jane Doe 119 SIBLEY AVE ARDM In MONTGOMERY County { 46 1} on or about 414 MARCH 2020 AT 1319 HRS. SO MERY_ (eno ts na; ee AOPC 412A - Rev. 07/18 with violating the penal laws of the Commonwealth of Pennsyivania at [_104 ] LOWER MERION TWSP Gael Ny Page 1 of 5804 POLICE CRIMINAL COMPLAINT als Ried, orepvescan Nurser ComplanWneaane Waar Wh oJ2© |UG393IN-S 2003140077 ‘ade Fk | TIFFANY (Docket Number CUFF 20 \Defendant Name TIARA Erol yee nel a te ba ono atin car) caged can oa din pty vba, wthoutme, pt a ane, Yu ren sn clas) ed acto hoa enn augedy veers socal ecty avin ora (ag Ps) ou tbe ety ean a mos bea Ista eae sae 207) Inchoate | [] Attempt 1D Solicitation ‘Conspiracy [Fostente | Cater Solita eae |pumer of ezine Age 60 or older gait a2 [orthe EC | ba — ST) — peas — eae poo aoc ‘Number L sotety zone TO Work Zone ssbtbh (hid ths mane OTEwIB of ofihancay KNOWLEDGE THAT PROPERTY IS PROCEEDS OF ILLEGAL ACT [Acls ofthe accused assoclaed with ths Ofonse’ DEALING IN PROCEEDS OF ILLEGAL ACTIVITIES [ine.Acter Tiara Brokenborough, in the County of Montgomery conducted a financial transaction under any of the following Fe somctances wit knowledge thatthe property invalved reprosents the proceeds of unlawful aciviy ar toe transaction [s esianed In whole or in part to conceal or dlaguise tho nature, location source, ownershinos oneness proceeds of nlawful actly in volaton of Secon 5111 (A) (2) of the Pennsylvania Grimes Gade, as amended, ieee gear AQ) [[icnonte | Chae In si ompt Cl Saliettion conspiney saat | ClaRamet soley Ci coneey umber of Viet Age 60 o Older 0 Gl [2 [a9 | a forme] ge] a | ae Se — wore prety ——core a rr vepneerror! 7 cident ponsog7 Dake] nae _ D0 Setety zone OO Work zone a in hens STRSTR] ———— a THEFT BY UNLAW TAKING-MOVABLE PROP cls ofthe acousod eesoclatad with ie Oflonsor THEFT BY UNLAW TAKING - MOVABLE PROPERTY [ro Actor Tlarah Brokenborough, inthe County of Montgomery, uniawfily took, or exercised unlawful contol over, movable ery gt another with Intent fo deprive him thereof in violation of Saction 3921 (A) of the Pennsylvania Cringe Code, as Eimenaea, 18 Pa.C.S, 3921 (A) Tachoate | DlAtenpt Ey Sais Generac ‘Offense, | U2 Attempt ‘esas rian Number of Victims Age 60 or Older 0 G03 | 3922 [at [ome] ae i Pr] ee ee PennDOT Data | Actldent C1 sarety zone 1D Work zone | with tis Oforse: SE IMPRESSION rest ctor Tarah Brokenborough inthe County of Montgomery, intentionally obtained propery of another by deception in lolatio of Section 3922 (A) (1) ofthe Pennsylvania Crimes ode, as amended. 18 ba @ sone “wm AOPC 412A - Rev. 07/18 Page 2 oF SM$ POLICE CRIMINAL COMPLAINT Docket Number —] Date Fs ‘OFWgyeSean Number Complainant Number 4 CL74-20 | Nfte[20 | "U'F3R3 145 2003140077 First idle ast Defendant Name TIARA ‘TIFFANY BROKENBOROUGH Inchoate | [] Attempt OF Solicitation Conspirac Seat | ClAttempt Solleitat eI | Number of victims Age 60 or Older G4 | 3922 A [ofthe 18 4 Fa, “one seen — sii FR Sa | tan — —ea — — oR LORROR PenaDOT Data] Accident x TOT Data] Axiant T Sotety zone OO work zone ‘Slalule Descrp ion ncaa ha warts Talat or oaiancs} THEFT BY UNLAW TAKING-MOVABLE PROP. [Acs oft accused associated wth Wis Offense [THEFT BY UNLAW TAKING - MOVABLE PROPERTY [The Actor, Tiarah Brokenborough, in the County of Montgomery, unlawfully took, or exercised unlawful control over, movable property of another vith intent to deprive him thereof In violation of Section 3821’ (A) of the Pennsylvania Crimes Code, as, ‘amended, 18 Pa.C.S. 3921 (A) Tnchoate ] [J Attempt TH Solicitation Cconspiracy Offense | 79 901'4 18902 4 Se o08 Number of Victims Age 60 or Older_O g 5 3922 A1__ forthe 18 4 Fa ee mBOT Data Resident TD surety Zone 1 worizone | ae Dover (aude Wer OT SA oO aRaTS ‘THEFT BY DECEP-FALSE IMPRESSION sof ra accused aszodtatd with ie Ofer [THEFT BY DECEP-FALSE [MPRES: [The Actor Tiarah Brokenborough in the County of Mentgomery, intentionally obtained property of another by deception in lolation of Section 3922 (A) (1) of the Pennsylvania Crimes Code, as amended, 18 Pa.C.S. 3822 (A) (1) Tnchoate ‘Attempt CO Solicitation Conspiracy |) ‘rtense’ | OU fssote 189024 woe Number of Victims Age 60 or Older _O Gals | 3925 | a [orm] a8 1 [| ne Sean Suits PA Bie | — Coon jade ~~ NOW Oh Code ~ UCRNIBRS Coie ennbgr bate [Aasaare TH sere Zone TI work one ear a = RECEIVING STOLEN PROPERTY cis of tho accused assooiated with tia Ofer ECEIVING STOLEN PROPERTY: 1e Actor Tiarah Brokenborough in the County of Montgomery, conspired to intentionally receive, retain, or dispose of Imovable property of another knowing that it has been stolen, or believing that it has probably been stolen, in violation of SSection 3925 (A) of the Pennsylvania Crimes Code, as amended, 18 Pa.C.S, 3925 (A) AOPC 412A - Rev. 07/18 Page 3 of 5482) POLICE CRIMINAL COMPLAINT Opgiet Wyaber ——] Bate Flea —— OrnyLveSearwamber ComplaniIncdent Number CRI 20 | Tle fa. [UR 2003180077 Fist dts Taek Defendant Name TIARA TIFFANY BROKENBOROUGH Tnehoate | Ej attempt Tr sollctation Conspire Oita: | ClAttemnt Sollctae Ciconspiracy umber of Victims Age 60 or Older _O OB, [7 | asoa az_fotte) 38 | F3 mse “Sean Subaaton PRS Tain "Grae ‘Oibnes Coie UCRMERT OS BannbOT Date] Acddent ad ree D safety zone TO Work zone Safule Daneiplon (elu Te nari of aalite ar arahanca rs thorized Act tn Writing elated wih this Oens colsed FORGERY [The Actor Tiarah Brokenborough on or about {n the County of Montgomery, with the intent to defraud or injure uniawfuly Imade, completed, executed, authenticated, issued or transferred one or more writings, namely, checks, so that It purported to be the act of another who dd not authorize that act, In violation of Section 4104 (a)(2) of the Pennsylvania Crimes Code, Act of [December 6, 1972, as amended, 18 Pa. C.S. 4101(a)(2) Inchoate | [] attempt: C1 solicitation Conspiracy G[ 8 | ane ore, ae 7 [| is ttt pre gras — es rr ects Pannbor bate] Aen (if applicable) | Number _ 1D Safety zone O work zone | sian Slate Descion meine Te nara of ‘SECURE EXECUTION DOCS BY DECEPTION [Acts of ie accused assodlatod wih his Offense: ISECURE EXECUTION DOCS BY DECEPTION [The Actor, Tiarah Brokenborough, in the County of Montgomery, by deception caused another to execute any instrument latfecting or purporting to affect or ikely to atfect the pecuniary interest of any person in violation of Section 4114 of the [Pennsylvania Crimes Code, as mended, 18 Pa.C.S. 4114 AOPC 44 2K- Rev. 07/18 Page 4 of 528% POLICE CRIMINAL COMPLAINT Becket Number Date Fed ~~] OTN/iIveScaq Number — ‘ComplaintineWdent Number CR7A-*% [It flejao | uw 14-5 2003140077 Fist? Middle Tae Petendant name | tara | aepany | BROKENBOROUGH 2. Task thet 9 warrant of arrest or 2 summons be issued and that the defendant be Tequired to answer the charges I have made, 3 LYrcrY thatthe facts set forth in this complaint are true and correct to the best of my knowledge or information and en ls Verification ls made subject to the penalties of section 4904 wi tea eee Code (18 PAC.C, 4904) relating to unsworn falsification to authorities. ‘4 THs complaint is comprised ofthe preceding page(s) numbered 1 through _4 5. Lcertiy that this fling complies with the provislons ofthe Case Records Public Access Policy of the Unified Judicial foram of Pennsylvania that require fling confidential information and decamenc differently than non-confidential information and documents. Comeana Committed by the accused, as listed and hereafter, were against the peace and dignity of the Caurmanwealth of Pennsylvania and were contrary to the Adt(s) of Assembie eras violation of the statutes cited, {Before a warrant of arrest can be issued, an affidavit of probable eeuse mua be completed, sworn to before the issuing authority, and attached.) Movember to, gogo | ny - (ostey (Signature of Aint) wae en tis date — LOL LOL F022 ___ cortty that tne complant has been Properly conpleted and verted An acavk of probable couse fust Be competed Before waar nen be 38107 Mahal be ! | (Wagistertal oistiet Court Womber) (ssulng Authorty) AOPC4I2A - Rev. 07/18 Page Sof 5Affidavit of Probable Cause Lower Merion Township Police Department Detective Edward Sarama, being duly sworn, according to law, does depose and say; Initial Investigation On March 14, 2020 the Lower Merion Police Department responded to a report of fraud at Hynes Roofing and Siding, 119 Sibley Avenue in the Ardmore section of Lower Merion Township, Montgomery County, Pennsylvania, The owners of the company, John and Michelle Hynes, were on location as well as. the company’s accountant, John Charbonneau. John Hynes is 67 years old and Michelle Hynes is 62 years old, Charbonneau stated that he was reviewing accounts with the Hynes when an American Express representative called regarding a Delta American Express credit card. The representative advised the Hynes that there was a $59,000.00 outstanding balance on the card. The Hynes believed that they cancelled this card approximately 18 months ago, The Hynes then began to review statements for this American Express card and found that it was being used from June 2019 to March 2020 without their knowledge. The account balances were being paid, without their knowledge, from their Bryn Mawr Trust checking account. While reviewing charges on the account, the Hynes found purchases for numerous flights to various locations, The name associated with these tickets was Tiarah Brokenborough, who is an employee of Hynes Roofing and Siding, The Hynes stated that Brokenborough has been with the company for seven years and acts as the “bookkeeper”. Brokenborough has access to all of the company crédit cards and financial accounts as she was tasked with paying all of the company bills. Michelle Hynes noticed that the name associated with one of the cards on the account was “Michelle Hines”, an incorrect spelling of her 1last name. She also noticed that the billing address for the card was changed from the company’address to 22 N. Rigby Avenue, Lansdowne, Pennsylvania. 22 N. Rigby Avenue is Tiarah Brokenborough’s listed address. American Express Records On March 17, 2020 1 was provided with account documents for the Hynes Delta American Express card. The documents showed charges dating back to October 1, 2018 totaling $242,460.31. The Hynes stated that they were unaware of these charges, and the payments were being made from the company checking account without their knowledge. I located eleven charges for plane tickets in the name of Tiarah Brokenborough, from August 2019 to February of 2020 to and from various locations in the United States. On April 11, 2019 the address for the American Express card was changed from the business address to Brokenborough’s address; 22 N. Rigby Avenue, Mailbox 3, Lansdowne, PA 19050. One of the phone numbers associated with the account, (484) 431-4059, belongs to Tiarah Brokenborough. The most recent email account associated with the Hynes American Express card was tiarah926@icloud.com. The following is a partial list of charges at various merchants taken . directly from American Express records: Apple Inc. I found numerous Apple Pay transactions on the Hynes American Express account. Apple Pay is a mobile payment and digital wallet service by Apple Inc. that allows users to make payments in person, in iOS apps, and on the web. It is supported on the iPhone, Apple Watch, iPad, and Mac, It digitizes and can replace a credit or debit card chip and PIN transaction at a contactless-capable point-of-sale terminal. The Apple ID associated with thecharges was listed as tiarah926@icloud.com. None of these charges were authorized by the Hynes. There was also $4,165.15 in charges through Apple retail, both online and in physical locations, using the Hynes American Express card. Airline Tickets ‘The following airline charges are associated with Tiarah Brokenborough: “JBROKENBOROUGH/TIARAH [SROKENSOROUGHMTIARAH | |SROKENBOROUGHMTIARAH | ~JBROKENSOROUGHTTIARAH | IBROKENBOROUGHTTIARAH [BROKENBOROUGHTIARAH ct a I a9 i 7 aaa ” JONES “OTrAOVaD | t [RO > ofyro7a5"[ PH “feat } ONESIROY~ ~JSONESIROYStubHub StubHub is a ticket exchange and resale company. It provides services for buyers and sellers of tickets for sports, concerts, theater and other live entertainment events. I reviewed the Hynes American Express account and found $28,803.49 in approved charges through StubHub that the Hynes did not authorize. On April 3, 2020 I obtained a search warrant for all StubHub accounts that utilized the Hynes’ American Express card numbers. | was provided with information on two separate accounts. The accounts used John or Michelle Hynes as the name on the account, but Brokenborough's home address as the account address. The email addresses used for the accounts were tiarah926@icloud.com and ttbrokenborough@gmail.com. arah Brokenborough was listed in the account contact list. The records provided also listed all of the purchases made through the accounts including the event type and prices of the tickets. PayPal \789 BEACOM LANE 4029357733 PA 19086" [739 BEACOM LANE 4026357733 PA 70086 ~~? [789 BEACOM LANE ~ 738 BEACOM LANE ™ BEACOM LANE 4026357733 PA 100 \739 BEACOM LANE “4028357733 PA 100 BEACON [ANE 4020357733 PA 190. $1208.55 [81588 PayPal is an American company operating a worldwide online payments system that supports online money transfers and serves as an electronic alternative to traditional paper methods like checks and money orders. 1 located the PayPal transactions in the chart above in the Hynes’ American Express records. A check of property records showed that the residence at 22 N. Rigby Avenue, Lansdowne, Brokenborough’s listed address, is owned byTimothy Leithead. Leithead’s listed address, according to PennDOT, is 739 Beacom Lane, Merion, Pennsylvania 19066, the same address listed in the above PayPal transactions. None of the charges were authorized by, the Hynes, On April 3, 2020 1 obtained a search warrant for PayPal records related ‘e the above charges. PayPal provided me with account owner information for the account that fraudulently utilized the Hynes American Express Card, The name listed on the account is Tiarah Brokenborough, DOB 9/26/1991, email tarah926@icloud.com, address 22 N. Rigby Avenue, Lansdowne PA 19080. The account was opened on January 11, 2017 and since then there has been $28,076.15 sent to various individuals and businesses from the account, PayPal also provided me with a list of credit card numbers associated with the account. Of the nine card numbers that were assigned to the Hynes American Express account during the duration of the time the account was open, six of thse account numbers were associated with Tiarah Brokenborough’s PayPal account, On July 28, 2020 I spoke with Timothy Leithead regarding Tiarah Brokeborough. Leithead stated that Brokenborough did reside at the N. Rigby Avenue address that he owns, Leithead stated that Brokenborough had not Paid rent since March and two of the payments from PayPal had been reversed for fraud, Leithead provided me with a copy of the lease showing Brokenborough as the lessee.Dr. Emily F. Pollard, MD FACS While reviewing the American Express records I located two charges at Pollard Plastic Surgery, 15 Presidential Boulevard Suite 102, Bala Cynwyd, PA 19004. The title of both charges was “Emily F. Pollard MD". The first charge was for $500.00 on May 17, 2019 at 11:47 AM. The second charge for $5,365.00 occurred on May 22, 2019 at 6:22 AM, The Hynes did not authorize cither of these transactions, Tcompleted a search warrant for records related to the above charges The warrant was signed on August 6, 2020 and served the same day. Dr, Pollard provided me with medical records related to the charges. The patient associated with the charges was Tiarah Brokenborough, with a copy of her drivers license and a photo of her taken by Dr, Pollard included in the medical records. The procedure performed was listed as ‘Liposuction of the torso, front and back with fat grafts to the buttocks’. Bryn Mawr Trust Records - Aller the Hynes discovered the fraudulent payments to American Express they began a systematic review of their checking account statements dating back to 2017. They found numerous items that they did not authorize such as bill payments and fraudulent checks. The total amount of fraud they observed at that time was $27,857.57, On April 1, 2020 I completed and served a search warrant for Bryn Mawr Trust account records pertaining to the Hynes checking account and Tiarah Brokenborough’s checking account, On April 15, 2020 I received and reviewed the records provided as a result of the search warrant, I found that all but one ofthe fraudulent checks were deposited into Brokenborough’s Bryn Mawr Trust checking account, The only check that was not deposited into Brokenborough’s account was check number 8917 in the amount of $1,000.00. I viewed the check image for that check and found that the checkwas not signed by either of Hynes, and the deposit endorsement on the back of the check was “For Deposit Only”, Bryn Mawr Trust could only verify that the check was negotiated against a PNC Bank account, I obtained video from the PNC bank where the check was deposited, The video showed an unknown white female depositing the check into the Hynes’ daughters checking account, Bryn Mawr Trust provided me with video from two of the fraudulent check deposits; February 11 and 21, 2020. The video is from behind the tellers and faces the customer. I reviewed the video footage and found that Narah Brokenborough completes both deposits into her Bryn Mawr ‘Trust checking acoount, Both checks were issued to “Cash”. While watching video I observed Brokenborough manipulating ther phone and navigating through applications, Frotn reviewing the video, | believe that Brokenborough was utilizing an iPhone. ‘The Hynes also advised me that there were multiple payments made to Capital One Auto in the name of Roy Jones. The payments were made on October 16, 2019, November 12, 2019, and March 16, 2020, The payments were in the amount of $592.50. During my review of the Hynes bank records I confirmed the above charges and located three more in the name of “JONESROY". The payments were made to Capital One mobile payment on January 14, 2020 for $150.00, January 23, 2020 for $25.00, and February 10, 2020 for $100.00, During further review of the Hynes checking account records I located multiple debits from "Marks Co Inc Rent" from June of 2019 to January of 2020. From iny experience, Marks & Co owns and operates numerous rental Properties in Lower Merion Township. I spoke with the Hynes and they confirmed that they do not rent any properties from Marks & Co and did not authorize any payments to be made to Marks & Co from their Bryn Mawr Trust checking account. The total of the six charges was $5,697.00.Tobtained check images from Bryn Mawr Trust and provided them to the Hynes. They reviewed checks from 2016 to 2020 and provided me with check numbers of fraudulent checks not authorized by the Hynes. Based on the Hynes review of their checking account, they determined that the total loss as a result of fraudulent checks and debits is $131,742.26, Marks & Co, Tcompleted @ search warrant requesting records related to the payments made to Marks & Co, through the Hynes Bryn Mawr Trust account. hat Warrant was signed on May 5, 2020 and served the same day on Marks & Co, ‘The company provided me information for five payments made with the Hynes’ checking account totaling $4,995.75. The apartment associated with the Payments was 900 Montgomery Avenue Apt, 409, Bryn Mawr, Pennsylvania 19010. The name associated with the apartment was Roy Jones Capital One T completed a search warrant requesting records related to the payments made to Capital One from the Hynes Bryn Mawr Trust account. The warrant was signed on May 6, 2020 and served on May 7, 2020. Capital One provided me with information for two accounts, both belonging to Roy Jones. The first account associated with the payments was an auto loan opened on April 12, 2019 and associated with a 2016 Lexus ES 350 (VIN S8ABK1GG6GU016321). I checked the VIN through PennDOT records and found that the vehicle was registered to Roy Jones. Three payments of $592.50 Were made to the account for a total of $1,777.50. The second account was a credit card account opened on April 16, 2019, Four payments were made from the Hynes account for & total of $375.00. The total loss for the Hynes related to Roy Jones and Capital One was $2,152.50. JP Morgan ChaseTcompleted a search warrant requesting records related to payments made to “CHASE CREDIT CRD EPAY” that the Hynes did not authorize. The warrant was signed on August 19, 2020 and served on the same day. JP Morgan Chase provided me with information for multiple accounts, dating back to 2016. I received 551 pages of statements related to multiple Chase cards belonging to the Hynes. I provided the statements to the Hynes and they conducted a review of all of the charges. The Hynes located alll of the fraudulent charges which totaled $20, 209.87. Apple iCloud Data Brokenborough's email address provided to multiple services was tiarah926@icloud.com, From my training and experience I know that the domain name iCloud is serviced by Apple Inc. Users typically use iPhones and other Apple Products which store information in the cloud on Apple's servers, While reviewing the Bryn Mawr Trust footage of Brokenborough making one of the fraudulent check deposits, I saw her using a cell phone, which in my opinion, was an iPhone, Based on my belief that Brokenborough was utilizing Apple's Cloud services, I completed a search warrant requesting iCloud records including, but not limited to, stored messages, photos, payments records, and device information. The warrant for this information was signed on May 5, 2020, and served on May 6, 2020, Treceived a file containing the requested materials from Apple on May * 12, 2020. One of the items that was provided were photos saved to Brokenborough's iCloud account. I viewed the photos saved to her account and compared them to records in my possession, such as the American Express charges and StubHub records. The photos provided by Apple have metadata associated with them. One of the items encoded on the metadata of the photos is the date and time the photo was taken, I compared the metadata of thephotos with the financial records and found that Brokenborough had taken photos of her activities while she was using the Hynes accounts fraudulently, ‘The most recent association I was able to find occurred on February 16, 2020, I located a screenshot showing a Frontier Airlines boarding pass for a flight from San Juan, Puerto Rico to Philadelphia, Pennsylvania, The names on the boarding passes were Tiarah Brokenborough and Roy Jones. Those tickets were purchased using the Hynes American Express card. On December 5, 2019 Brokenborough took a photo of Roy Jones sitting in the front row of a Philadelphia Flyers game. The tickets for that game were purchased using the StubHub service for $485.00. StubHub was paid using the Hynes American Express card. On October 23, 2019 Brokenborough and Jones attended a Philadelphia ‘76ers game and took photos of themselves at the game. The tickets were purchased using the StubHub service for $1,385.00, StubHub was paid using the Hynes American Express card, Ilocated multiple photos of Brokenborough and Jones taken from October 19, 2019 to October 22, 2019 in Dallas, Texas, I located numerous charges related to this vacation, all of which were paid for with the Hynes American Express card. These charges included tickets to a Dallas Cowboys _ game for $1,755.00, a hotel charge for $283.73, an AT&T Stadium hospitality charge of $350.59, and a Dallas pro shop charge of $340.94. The total of these vacation charges was $2,730.26. On January 21, 2019 Brokenborough took a screenshot of an Instagram conversation with a user named “youngdriz24”, In this conversation “youngdriz24” sent Brokenborough a photo of Brokenborough and Jones on television at a basketball game, I checked StubHub records and found that there wes a purchase of Philadelphia 76ers tickets for that date. The amount of 10the ticket purchase was $462.70 and was paid using the Hynes American Express card. Tocated a photo and a video of Brokenborough at what appeared to be a nightclub dated September 21, 2018. I checked the American Express records and found two charges on that date at two nightlife locations, The first charge was at Bleu Martini for $337.56 and the second charge was for $300.00 at Club Indie, for a total of $637.56, ‘The final photo I was able to associate with charges was dated September 15, 2018. There were multiple photos taken of Brokenborough and Jones at a stadium. Using the photo metadata I located a StubHub transaction with an event on that date. The event was a “Drake with Migos” concert and the tickets were $695.15. The tickets were paid for using the Hynes credit card, also located a screenshot in Brokenborough’s photos which showed an Instagram conversation with a user named “saydi_nei”. In the conversation “saydi_nei" claims that “Roy” slept at her house and made statements about Brokenborough, “saydi_nei” stated that “Roy” told her that he only uses Brokenborough for her money. Conclusion On March 14, 2020 the owners of Hynes Roofing and Siding, John and Michelle Hynes, reported an ongoing theft to the Lower Merion Police Department by an employee, Tiarah Brokenborough. The Hynes employed Brokenborough as a bookkeeper and entrusted her with the financials of the company, giving her access to all of the company financial accounts. The Hynes found $242,460.31 in fraudulent charges on their American Express credit card dating back to October of 2018. The American Express card was paid using the Hynes Bryn Mawr Trust checking account. The Hynes also located $20,209.87 in fraudulent charges on their Chase cards, unThe Hynes reviewed their Bryn Mawr Trust checking account and found found numerous other fraudulent charges, payments, and checks related to their business checking account. This included, but is not limited to, $26,857.57 in fraudulent checks deposited into or cashed against Tiarah Brokenborough’s Bryn Mawr Trust checking account. Items in the records also indicate that payments were made for accounts belonging to Roy Jones as well, which the Hynes did not authorize. The total loss associated with accounts owned by Roy Jones is $7,148.25. The total loss for the Hynes related to their Bryn Mawr Trust checking account was $131,742.26. As a result of my investigation, I believe that Tiarah Brokenborough is responsible for the theft of $394,412.44 from Hynes Roofing and Siding by way of fraudulent credit card use and theft from the company checking account. Brokenborough was in a position of trust in the company as the bookkeeper and used that trust to gain access to the Hynes personal information and business accounts. She used those accounts to finance fine dining, vacations, attendance at sports events and plastic surgery. Furthermore, I believe that Roy Jones took advantage of Brokenborough’s access to this information and used it to pay for his rent, auto loan, and credit card bills. Based on the above information, I request that Tiarah Brokenborough be charged with the aforementioned violations of the Pennsylvania Crimes Code. Fey —U/1o/40a0 Detective Edward Sarama Date Sworn to and subscribed before me this /¢ day of November, 2020. Ved A Magisterial District Justice My Commission Expires: //7?/P4Zc/ __ 2Confidential Information Form CONFIDENTIAL sh Criminal Complaint he NCTE Coane ent SEN Information If known, 1 ths form i submitted as pare ota [De NEIE Ceutlone/Medleal Conditions and Scare/Marks/Fatoosvecians MoulDahe be are ie ey epee 5 | are aS SR aren ber ateredy Complaint Incident Nurmber cS Ufjojro 2003140077 Defendant Name |" tara [mea TIFFANY ost BROKENBOROUGH — NCIC Cautions and Medical Conditions (check uaa 9) — & 00 O2 OD s0 0 70 Oi ot - other Cos Os Oss Oe Ow Ds Oe Oes Os O« Os Oe Scars, Marks, Tattoos (Ncrc codes) decomp tothe Case Records Pubic Access Poley oF the Unified Juice System oF Pennsylvania, the Confidential Information Form shall af a matter Tis regen aentil information is required by lan, ordeved by the conrh orien necessary to effect the disposition the eur se ay Bn actionalpoges, shal remain Conteris exe Bear eo available to the parties, counsel of record, ‘he cours and the custodlan, This form, and any additonal pages, must ns sessoy eave parties and counsel of record This Form Pertains to: Confidential information: Reference in Filing: srorenaoroucn, airy | OH Sear Huron (si ‘arate Reece: (full Name of adult) ‘Financial Recount Number (FAR)? Alternate Reference: on This information refers to a minor with the Driver's License Number (DLN): Alternate Reference: inno "ond te a sah me srt = Sate of Tasuance (OLN): ‘(hull Name of aduit) ‘ PA » Bnd date of ren; | Bares SER} [ State Hdenicaton Number (ID; ——— 'arernate Reterence: Addonal peges attached. @ total pages atached to tis fing Poanayutnas is Meg comes wth the provisions of the Case Records Public Access Poly, ofthe United Judiciat System of Pennsylvania 3. secure fing confidential information ate document UiferenGy Win See ce he oe ee ‘and documents, # [44 U/ 10, oa Nome: DETECTIVE EDWARD saRANA Acres: LOWER MERION POLICE storey Humber (ata) ee AOPC 412A - Rev 07/18 Page i of f