Professional Documents
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STATE O F
M O N TANA/
) Cas e N o . : DC - 1 5 - . l
f'f g
Plaintiff,
) A FFIDAV IT O F
P R O B ABLE CAU SE AND
) M OTION F O R L E A V E T O F I L E A N
) I N F O RMATI O N
vs.
L LOYD D O U G L A S
)
)
WALTERS,
)
)
D efend a n t .
)
COMES NOW the undersigned, and being first duly sworn upon oath,
d eposes
a n d s a y s as f o l l ows :
1687 No rth 1 9
in B o zem a n , G a l l a t i n C o u n t y , M T .
s o,
but
D efendan t
newspape r
r ac k s .
o n t h e r a c k s . However ,
B o n n a n d c o n c e d e d t h at
t h e n ew l o c k s
on the racks were actually old locks that BDC had used in the
past. Bonnand also informed that BDC only empties the money from
the racks every couple of weeks, despite the papers being
delivered six days a week. Bonnand also stated that since the
thefts began, he had gone to
s evera l
a B DC m ac h i n e .
on 919 W. College in
Bozeman that the Defendant had been spotted at a BDC rack and had
since left westbound on College. Bonnand stated that he had then
gone to the Casey's Corner at 4135 Valley Commons in Bozeman
where he found the money from that BDC rack to be missing.
Bonnand noted that he had checked that same Casey's Corner rac k
on April 26, and that the money had not been
r emoved .
r ac ks .
W it h
Conoco a t
machine was also missing. Bonnand then went to the Town Pump at
1871 Baxter in Bozeman to wait for the Defendant.
10. Frederick told Det. Green that at the IHOP,
at
o btai ne d a s
part of the
of
t h e ke y s o n t h e
some were to the locks BDC had changed out after the thefts
began .
12. Det. Green noted that the Defendant's keys w ere e n t e r e d
into evidence along with the container o f
Defenda n t '
ch ange f ou n d o n t he
H u tc h i n g s ,
t ot a l e d
$4 7 . 1 2.
13. Det. Green then met with the Defendant, reading him his
Miranda rights, and the Defendant agreed to
speak
w i t h o u t an
rack
a rr e s t e d ,
B DChad
emptied all of the BDC newspaper racks which the Defendant could
access and found a total of $8 .00 in all of the machines
t h e R e d C h a ir
Cafe in Bozeman which was added after the Defendant was fired and
one from the machine in front of the BDC building which requires
a special key which the Defendant did not have a cces s
informed that $29.00 was
t o . Bo n n a n d
suf f e r i ng
r eco v e r e d
f r om
machines which the Defendant did not have access to, he estimated
the total losses of the Defendant's actions to be
$9,976.50. Bonnand stated he would provide a
approximately
s pre a d s h e e t
n um b e r s .
Na y 1 9,
20 1 5 B o n n a n d p r o v i d e d a s pr e a d s h e e t
t o De t .
of
th e
(Ap r i l
28, 2015), BDC had collected a total of $419.73 from its fifty
four (54) machines in Bozeman. Bonnand's numbers showed that in a
single week after the Defendant was arrested, B DC had c o l l ec t ed
$ 699.5 2
i n n ew s p a p e r r a c k sa l e s . Bo n n a n d ' s spre a d s h e e t s
s t at ed
amount of p ap e rs
that had been taken from BDC machines should have totaled $7,949
i n sa l es .
without being paid for. Bonnand's estimate for the total losses
from BDC newspaper racks during the range from February 3 to
April 28, accounting for the average 10% theft rate, was
$ 6, 734. 37 .
17. During his investigation, Det. Green also made contact
with a number of employees working at BDC newspaper rack
l o c a t i on s .
18. Rosa Bustamante, an employee of Casey's Corner at 1420 N.
7',
t he pas t .
t h e "regular guy" pull upon and take money out of the BDC
s cheme,
a Fe l on y ,
i n
Dated t h i s
~l
2 . $day o f
2015.
r ego r y
Deputy County At t
m e o n t his 2
NOTARY
,es&taaaer
,"",'i~,E. o "'.
CHRISilNE RICHARDS
fVotttry Public
= o.' 6 OTAR>gf .'.(jg ' for the State of Montana
a Ii af' Ie i
Ae 'iciing at:
Manhattan, Montana
My Cornrnission Expires:
February I5, 2015
ey
day of
2015.