ARREST WARRANT APPLICATION

JD-eR-64b' Rev.3-11

For Court Use Only

STATE OF CONNECTICUT

C.G.S. $ )4-2a
Pr. Ek. Sec. 36-1, 36-2, 36-3

Supporting Affi davits sealed

f,ves

SUPERIOR COURT
www.jud.ct.gov

Truo

number

14-149s3

Derby Police Department

Name (Lasl

Court to be held at (Tawn)

Gaillard, Gregory

Derby

Geographical

Area number

Application For Arrest Warrant

To: A Judge of the Superior Court
The undersigned hereby applies for a warrant for the arrest of the above-named accused on the basis of the facts
set forth in the:
Affidavit Below.
Affidavit(s) Attached.

C
L.)

name of prosecuting

5i

fl-s

Affidavit
The undersigned affiant, being duly sworn, deposes and says:

The undersigned, Detective Edward Sullivan 060, being duly sworn, does depose and state that he is a member of
the Derby Police Department and has been since 812712007. At all times mentioned herein he was acting as a
member of said department. The following facts and circumstances are stated from personal knowledge and
observations as well as information received from other police officers acting in their official capacity and from
official police reports and statements made by prudent and credible witnesses.

on 1211212014 this writer met with members of the Derby Administrators Association herein after known
as DAA, at Derby Central Office located on 5th Street in Derby. Members of the DAA include Irving School
Principal Jennifer Olson, Bradley School Principal Mario Ciccarini, Special Education Supervisor Shelly
Sherridan,Interim Derby Middle School Vice Principal Rachael Artaiz, and Interim Derby High School Principal
Martin Pascale. This writer was informed that money is believed to be missing from the DAA Webster Bank
account #0009800690. According to the members of the DAA, $13,200.00 was unaccounted for. This became
known as Derby Police Department case#14-14953.
1. That

2. That members of the DAA stated that unexplained withdrawals began in2073. At the time of this meeting the
DAA Greg Gaillard had control over all financial aspects of the account from7l2l20l3 to
1211212014. At the conclusion of this meeting DAA Vice President Ciccarini restructured the Webster Bank
DAA account and eliminated Greg Gaillard from the account.
President of the

3. That the DAA members include but are not limited to administrators of the Derby School District including
Principals, Vice Principals, and Social Workers. The account is set up to assist its members with Union
representation and emergency funds for its members. The members make bi-weekly contributions directly from
their paychecks and deposit the money into Webster Bank account #0009800690. A monthly payment is made to
the AFL-CIO and the remainder stays in the account. According to the DAA members, at the end of the year
money from the account would be divided amongst the members usually before Christmas break. The members
stated there is no clearly defined rules regarding the distribution of the remaining funds from the account but the
(This is page 1 of a 5 page Affidavit.)

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Subscribed aDd swprn to before me on (Date)

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Court, Notary Public)

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Finding
The foregoing Application for an arrest warrant, and affidavit(s) attached to said Application, having been submitted to and
consi-dered.by the undersigned, the undersigned finds from s'aiO affidavit(s) that th'ere is probable ciuse to believe that
an offense has been committed and that the accused committed it and, therefore, that probable cause exists for the
issuance of a warrant for the arrest of the above-named accused.
Date and
Signature

Name of Judqj:/Judoe Trial Referee

BRQvvN, J,

ARREST WARRANT APPLICATION

JD-CR-64a Rev.3-11
c.G.s. s 54-2a
Pr. Bk. Sec. 36-1, 36-2, 36-3

STATE OF CONNECTICUT
SUPERIOR COURT
www.jud.ct.gov

Name (Lasf, First, Middle lnitiat

Geographical

Gaillard, Gregory

Area

number 5

Affidavit - Continued
President of the account would distribute the money according to the balance remaining.

4. That previously on 12/9114 Gaillard resigned his position as Derby High School Principal. This resignation is
believed to be unrelated to the facts and circumstances of this report and the DAA. Later that night following his
resignation, Pascale received a text message from Gaillard requesting he retrieve and put aside Webster Bank
statements that were in his office. Pascale immediately contacted Derby School Superintendent Dr Matt Conway
to inform him of the request Gaillard had made. Conway instructed Pascale that no one is to enter Gaillard's
former office. Pascale did not enter the office. Conway later responded to the Derby High School and recovered
several Webster Bank statements from Gaillard's office.
5. That on l2l1ll20l4 Olson received a phone call from Conway asking about the DAA Webster Bank account.
Based on the three monthly bank statements Conway had recovered from Gaillard's office, Conway inquired
about who had access to the account and whether or not there should be frequent withdrawals. Olson confirmed
that Gaillard was the only approved member of the DAA with access to the DAA Webster Bank account and

checkbook. The content of the three bank statements raised enough concern that it prompted a review of past
bank records. Olson and Ciccarini went to Webster Bank in Derby and requested the past statements of the DAA
account from July 2013 to present which was the time period that Gaillard gained sole access to the account.
After reviewing the statements from July 2013 to present it was determined that $13,200.00 is unaccounted for.
These transactions include cash withdrawals directly from Webster Bank and checks written directly to Greg
Gaillard and endorsed by Greg Gaillard. These transactions occurred between 1012812013 and 1112612014.
Members of the DAA can confirm that most of the transactions were handwritten in Gaillard's handwriting
however most recently there are several checks written out to Greg Gaillard and endorsed by Greg Gaillard but
the handwriting and signature is clearly not the same. It was undetermined at this point who signed Gaillard's
name on four checks written out to Greg Gaillard.
6. That following the 1211212014 meeting with

DAA members at Central Office, Ciccarini and this writer met

with Webster Bank Vice President Patricia Casini. Ciccarini provided Casini with documentation to remove
Gaillard from the DAA account and lock the account for deposits only. Casini provided Ciccarini with copies of
statements from the DAA Webster Bank account #0009800690 from 7/212013 to 1211212014. Casini also
confirmed that the account was set up for one signature only for withdrawals and cashing checks from7l2l20l3
to 1211212014. Ciccarini added the second signature to the account for all future transactions. Upon reviewing
the DAA account statements provided to this writer from Ciccarini it was confirmed that regular bi-weekly union
dues were deposited in the amount of approximately $454.50. The total amount deposited is determined by the
number of school administrators contributing at $103.00 per month. Each month a check would be written to the
AFL-CIO for union dues by the account administrator. The account administrator from 71212013 to l2ll2l20l4
was Greg Gaillard. Also, at the end of each month a monthly service charge would be deducted from the account
by Webster Bank. The remainder of the money would remain in the account and could be used for special
occasions or emergencies involving one of the members. On l0lll2013 the DAA account had a balance of
(This is page 2 of a 5 page Affidavit.)

Date

a/to ltt'
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Notary Public)

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ARREST WARRANT APPLICATION

JD-CR-64a Rev. 3-1

C.G.S. $ 5a-2a
Pr. Bk. Sec. 36-1,36-2, 36-3

STATE OF CONNECTICUT
SUPERlOR COURT
www.jud.ct.gov

Name (Lasf, First, Middle

Geographical
Area number

Gaillard, Gregory

Affidavit - Continued
$4,995.61. Regular bi-weekly deposits were made each month until t21512014. As of 1218/2014 the balance of
the DAA account was $55.76 . On l2ll5l20l4 Olson contacted the AFL-CIO and confirmed that their Union due
balance was behind approximately $2,000.00. Further review of the account indicates there are 13 transactions
that can not be explained. Most of the transactions have notes on the checks which include such things as nego
(negotiations), end of year party, shirts, welcome back dinner, and party. Members of the DAA have confirmed
that no such dinners, parties, or shirts were ever purchased, talked about, or agreed upon amongst its members.
7. That this writer confirmed with Webster Bank that the transactions were both withdrawals from Webster Bank
and cashed checks at banking institutions. Webster Bank also confirmed that video and additional information
can be obtained via Search Warrant to help confirm the identity of the depositor and the bank for which the other
transactions were made.
8. That onl2l22ll4 this writer contacted Gaillard via telephone and left a message on his voicemail. Within
minutes Gaillard called this writer back. This writer explained to Gaillard that I had received a complaint from
the members of the DAA regarding missing funds. Gaillard immediately responded "oh that, I am actually
meeting with Ciccarini and Olson tonight to discuss that". I asked Gaillard what time that meeting will be taking
place and he responded around 4:00 PM. Gaillard asked me if it was possible for this issue to just go away or be
handled without police involvement. I explained to Gaillard that the police were already involved but if the
meeting with the members results in a change from the complainant I would need to be notified immediately.

9. That the following day onl2l23l14 this writer met with members of the DAA to discuss the missing funds
from the Webster Bank account. Olson and Ciccarini confirmed that they had met with Gaillard on 12122114 at a
Starbucks in Hamden. Ciccarini stated when they met with Gaillard he informed them that he had deposited
$3,000.00 back into the DAA account in an attempt to repay the money he had taken out. Ciccarini later
provided a Webster Bank statement and deposit slip confirming thata $3,000.00 deposit was made into the DAA
account on 1212212014 at 10:26 AM prior to their meeting. At the time of this meeting the DAA Webster Bank
account was set up for deposits only and Gaillard was able to deposit the money prior to their meeting. Ciccarini
and Olson stated that Gaillard did not seem to understand the seriousness of the money taken from the account
and was unsure exactly how much was taken. Ciccarini informed Gaillard that $13,200.00 was taken out of the
account. Gaillard went on to tell Olson and Ciccarini that he was "son), things got out of control". Gaillard told
them both he was struggling financially. Ciccarini stated that he asked Gaillard about the different signatures on
the front of the checks written out to him and Gaillard stated that he intentionally signed the checks differently in
case anyone became suspicious of him. Ciccarini explained to Gaillard that he needed to talk this out with all the
members of the DAA and everyone needed to be in agreement as to what to do. Olson provided this writer with a
signed statement regarding their meeting at Starbucks. Olson went on to say that after speaking with all the
members of the DAA they wished to sign a formal complaint to pursue charges against Gaillard. Olson was
informed to freeze the account and that the $3,000.00 deposited into the account by Gaillard was now evidence.
Ciccarini stated that following the meeting with Gaillard he received a text from Gaillard stating "Ok. I have the
(This is page 3 of a 5 page Affidavit.)

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Subscribed ?nd syorn to before me on (Date)

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ARREST WARRANT APPLICATION

JDCR-64a Rev.

STATE OF CONNECTICUT

3-11

SUPERIOR COURT

C.G.S. S 54-2a
Pr. Bk. Sec. 36-1, 36-2, 36-3

www.jud.ct.gov

Name (Lasf, First, Middle Initia\

Geooraohical

Gaillard, Gregory

Area'number 5

Affidavit - Continued
10k"and "I will have Cashier check tomorrow for 10k". Ciccarini later responded, "Greg - we met as a group
with the police and it is in their hands now". Ciccarini provided me copies of the text conversation between him
and Gaillard.
10. That Olson provided the following list of withdrawals and checks that were not authorized:
$ 4,700.00 1012812013 cash withdrawal to Greg Gaillard.
$ 700.00 1111212013 cash withdrawal to Greg Gaillard.

$ 1,000.00

ll2|l20l4

Check #1070 to Greg Gaillard

$ 500.00 31712014 Check #1073 to Greg Gaillard
S 1,900.00 412512014 Check#1075 toGregGaillard
$ 1,500.00 612712014 Check #1077 to Greg Gaillard
$ 300.00 712912014 Check #1078 to Greg Gaillard
$ 400.00 911812014 Check #1079 to Greg Gaillard
$ 400.00 912612014 Check #1080 to Greg Gaillard
$ 300.00 10/1412014 Check#1081 to Greg Gailtard
$ 400.00 10/2712014 Check #1082 to Greg Gaillard
$ 600.00 1Il7l20l4 Check #1083 to Greg Gaillard
$ 500.00 1112612014 Check#1084 to Greg Gaillard

(memo:
(memo:
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Gift ).
EndofYearParty/Gifts)
End ofYear Party)
Shirts)
Welcome Back Dinner)
Nego)
Dinner)
Party)
Halloween Party)
Union)

The first two transactions which took place on October 28,2013 for $4,700.00 and November 12,2A13 for
$700.00 were cash withdrawals directly from Webster Bank. Both withdrawal slips were endorsed with Greg
Gaillard's signature. The remaining 11 transactions were written out to Greg Gaillard and endorsed on the back
with Greg Gaillard's signature. Members indicated that if there was a party or a Union negotiation situation in
which the money needed to be taken out the remainder of the members would be aware of it. The members
confirmed that no parties or negotiations had taken place as the memo's on the checks indicated.
1 1. That on 111312015 this writer obtained a signed Search Warrant for records for Webster Bank Derby
Administrators Account #0009800690. The warrant was served on 111312015 at Webster Bank 500 New Haven
Ave Derby to Vice President Patricia Casini. On 112612015 this writer received Webster Bank statements for the
Derby Administrators Account (DAA) #0009800690. This writer reviewed the documents received from
Webster Bank and confirmed that on71212013 Greg Gaillard completed and signed all necessary forms making
him President of the Derby Administrators Association account #0009800690. The documents were all endorsed
with Gaillard's signature.

12. That upon review of the documents provided by Webster Bank this writer determined that of the 13
unexplained transactions, 4 of the checks were written out to Greg Gaillard and signed on the front by Greg
Gaillard. The writing and signature clearly did not match Gaillard's hand writing as the members previously
stated. However, after receiving the documents from Webster Bank, the back side of the 4 checks is clearly
(This is page 4 of a 5 page Affidavit.)

Date

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Subscribed andFworn to before me on (Date)

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ARREST WARRANT APPLICATION

JD-CR-64a Rev. 3-1'l
C..S. S s4-2a
Pr. Bk. Sec. 36-1, 36-2, 36-3

STATE OF CONr\IECTICUT
SUPERIOR COURT
www.jud.ct.gov

(Last,

Geooraohical

AreJnumber 5

Gaillard, Gregory

Affidavit - Continued
visible. The back of the checks clearly show Greg Gaillard's signature as the endorser of the checks at the time
they were cashed. This confirms what Gaillard told Ciccarini and Olson on L212212014 at their meeting at
Starbucks in Hamden. There were originally some questions as to whether or not someone else may have been
cashing checks from the account using Gaillard's name but after receiving the copies of the back side of these
checks it is believed that Gaillard did intentionally alter his writing and signature on the front of the 4 checks but
used his actually signature at the time he cashed the checks. This writer attempted to obtain video surveillance of
the 4 transactions under the Search Warrant but according to Webster Bank no video surveillance was available.
13. That further review of the documents confirm that there are atotal of 13 transactions which took place
between October 28,2013 and November 26,2014 that the DAA members determined to be unexplained. All 13
unexplained transactions were endorsed with Greg Gaillard's signature which matched the signature used when
Gaillard signed the forms making him President of the DAA on7l2l20l3 and also confirmed by DAA members
to be Greg Gaillard's signature.

14.That it has been determined through this investigation that Greg Gaillard was the president of the Derby
Administrators Association and had sole control over Webster Bank account # 0009800690 from 71212013 to
T2ll2l20l4. That during this time 13 unexplained transactions took place in which $13,200.00 was taken from
the account without consulting the DAA members and with no attempt to repay any of the money taken from the
account during this 17 month time period. Not until Gaillard was confronted with the reality that he may be
arrested did he make an attempt to make partial reimbursement for the money taken.
15. That this writer believes that probable cause has been demonstrated and respectfully requests that an arrest
warrant be issued for Gregory Gaillard l0l2ll977 for violation of Connecticut General Statues 53a-123 Larceny
in the Second Degree.

(This is page 5 of a 5 page Affidavit.)

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