AMENDED COMLAINT

TAB CHARGE PREVIOUSLY FILED

STATE OF
MINNESOTA,
PLAINTIFF,
vs.
NAM: Fist, Middley Last
Cheryl Ann Tchida
7169 Windgate Road
Woodbury, M 55125-1529
Ct Statute Type Offense
Date
I ChrgPenalty 9/15/11
Statute Number & Description
609.611 Subd. l(a)(I) Insurance
Fraud-Present False
RepresentationConceals Facts-Policy
A cation
ua1rrtru rRoscu1oR csar:ri|ena.
rrno.
CR-2012-1277
Summons
Date of Birth
0411711962
DEFENDANT
Offense MOC GOC Controlling Control
Level A_encies Numbers
F U1112 N M062095Y 12000393
Your complainant, Jonathan Ferris, is a swor peace offcer and a detective with the Division of Insurance Fraud
Prevention (hereinafer 'IFD') of the Minnesota Department of Commerce. In April 2012, the IFD received a
suspected insurance faud repo1t, submitted by State Fatm Mutual Auto Insurance Company (hereinafer, 'State
Farm'), concerning Cheryl AnTchida (hereinafer 'Tchida'). As a result of that report, Detective Ferris was
assigned to investigate the alleged crime of insurance faud.
In June 2011, Fam1er' s Insurance cancelled a homeowner' s insurance policy on Tchida' s home, located at 7169
Windgate Road, in the City of Woodbury, County of Washington, and State of Minnesota. On September 15, 2011,
Tchida applied fr a State Farm homeowner's insurance policy with the Chad Crow Insurance Agency, located in
Woodbury. State Farm Agent M.C. accepted the application verbally over the telephone. As per the State Farm
insurance application, M.C. was required to ask Tchida questions concering: her most recent insurer; priodosses
(claims); and whether she had convictions fr arson, fraud, OJ other insurance related ofenses. In response to those
.questions, Tchida withheld material infrmation from M.C., who is an appointed agent fr State Farm. Particularly,
Tchida stated in her application that her most recent consecutive period of time with her prior insurer was fom
09/2006 through 09/2011, however her prior insurer (Farmer's) cancelled her insurance policy in 06/2011. Tchida
then denied having had any insurer or agency cancel her insurance within the past 3 years. Tchida also replied "NO"
when asked if she had been convicted of arson, faud, or other insurance related ofenses, however on 01/05/2011
Tchida was convicted ofinslUance Fraud in Washington County District Court (82-CR-10-687). Tchida was also
asked if she had any losses, insured or not, in the past 5 years. Tchida's application indicates that she admitted to 3
losses in the previous 5 years, however upon frther investigation it was discovered that Tchida had at least 8 claims
fr losses within the previous 5 years, Based on the flse infrmation provided by Tchida, State Farm issued her a
homeowner's insurance policy on September 15, 2011.
On or about February 5, 2012, Tchida's home sustained water damage purportedly as a result of a washing machine
discharge hose. Tchida fled a claim with State Fmm related to the loss. State Farm dispatched ServiceMaster
Cleaning & Restoration in an efort to mitigate damage to the home and property. State Farm paid ServiceMaster
$6;663.53 fr restoration services. A State Farm SIU investigation concerning Tchida's application fr insurance
discovered the fllowing: her Fanner's Insurance had been cancelled several months earlier than reported, she did not
inf1m Crow of all prior claims, and she filed to truthflly answer whether she had been convicted of arson, faud, or
other insurance related ofenses. Based on those fndings, State Farm cancelled Tchida's policy. As a result of the
material misrepresentations made by Tchida, State Farm has suffered a monetary loss of $6,663.53.
The fregoing facts constitute your Complainant's basis fr believing that on or about September 15, 2011 in
Washington County, State of Minnesota, the defndant, Cheryl Ann Tchida, (DOB: 04/17/1962), did wongflly,
unlawflly,
Countl
Charge: Insurance Fraud-Present False Representation/Conceals Facts-Policy Application
In Violation of: 609.611 Subd. l(a)(l)
Penalty: ten years or $20,000.00, or both
with the intent to defaud, presents any infrmation that contains a flse representation as to any material fact
concering a claim fr payment or beneft under an insurance policy, and the value of the beneft wrongflly obtained
or attempted to obtain exceeded $2,500.00.
M|atsata:ja:tn:atarcae:ee
- t G1 r j
Peter S. Johnson
Assistant Washington County Attorey
Attorney Registration #: 0392009
rRosrcuT|nc 11oRnrsscnnTuR
Washington County Goverment Center, 15015 62nd Street
North Stillwater, M 55082
(651)430-6115
Court Case#:
This COMPLAINT was subscribed and swom to befre the undersigned this J day ofL __

_____
NAME:
'"
LESLIE MILAN
Stole of 'Minnesota
Signature:
Title:
& Notary Public
My Commission Expires
:;u Jon Uor Y 3 l . 2 O l 5

n o o L L u
_

From the above swor fcts, and any supporting afdavits or supplemental sworn testimony, I, the Issuing Ofcer, have determined that
probable cause exists to support, subject to bail or conditions ofrelease where applicable, Defendant(s) arrest or other lawfl steps be taken to
obtain Defndant(s) appearance in Court, or Defndant(s) detention, if ah'eady in custody, pending frther proceedings. The Defndant(s) is/are
thereof charged with the above stated ofense(s)
ummoxg
_THEREFORE, You, THE ABOVE-NAMED DBFENDANT(S), ARE HEREBY SUMMONED to appear on the
day of
,
at

AM/PM befre the above-named court at 14949 62nd St. N., Stillwater, Minnesota
to answer this complaint.
IF YOU FAIL TO APPEAR in response to this SUMMONS, a WARRANT FOR YOUR ARREST shall be issued.
_An_

_XECUTE I MINNESOTA ONLY _EXECUTE NATIONWIDE _EXECUTE IN BORDER STATES
_To the sherif 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 Defndant(s) be apprehended and arrested without delay and brought promptly befre the above-named
Court (if in session, and if not, befre a Judge or Judicial Ofcer of such Court without unnecessary delay, and in any event, not later than 36
hours afer the arrest or as soon thereafer as such Judge or Judicial Oficer is available) to be dealt with according to law.
puurnoruzizNito]
_Since the above-named Defndant(s) is/are already in custody; I hereby order; subject to bail or conditions ofrelease, that the
above-named Defendant(s) continue to be detained pending fher proceedings.
I
Bail:
Conditions of Release:
This Complaint is duly subscribed and swom to, is issued by the undersigned Judicial Ofcer this _____ _
day of _________
unmv |gaat:::
TITLE: 1aegeatuistriecar:
the fllowin witnesses:
STATE OF MINNESOTA, COUNTY OF WASHINGTON
Clerk's Signature or File Stamp:
RETURN OF SERVICE
J
STATE OF MINNESOTA
Plaintif
vs
I hereby Certif and Retur that I have served a copy of this
COMPLAINT upon the Defndant(s) herein-named.
Cheryl Ann Tchida
Defndant(s)
Signature of Authorized Agent: