AFFIDAVIT OF CONSTANCE SMITH
My name is Constance Smith. I am over the age of eighteen (18) years and am fully
competent to testify to the matters stated in this affidavit. I have personal knowledge of
the facts and statements contained in this affidavit and each is true and correct,
In or around July of 2016, I was elected “Hash Cash” AKA Treasurer of the social
club commonly known as the Humpin’ Hash House Harriers located in San Diego
County, California. The election was for approximately one year. The Humpin’ Hash
House Harriers operates as a non-profit organization. During the same election, Tony
Lieras (AKA “Spedophile”) was elected Grand Master “GM” AKA General Manager of
the above said social dub.
My duties as “Hash Cash” included but were not limited to the following:
(1) Collecting weekly run fees and special event fees;
(2) Maintaining a record of the number of people to attended weekly runs and
special events;
(3) Maintaining a record of individual ran numbers;
(4) Reimbursing for club expenses i.e. food and drinks;
(6) Establishing and maintaining a bank account;
(6) Projecting a budget for special events; and
(7) Determining weekly profits/losses.
Inoraround November of 2016, the Humpin’ Hash House Harriers held a special
event known as Hash-A-Thon. The event consists of four (4) running trails back to back
in one day. The special event run fee was forty dollars ($40). Individuals participating in
the event were promised to receive in exchange for their run fee of forty dollars ($40),
four (4) trails, lunch, dinner, snacks, beverages, and a T-Shirt. In addition, if the
individual completed all four (4) runs, they were promised to get their name on the T-
shirt. Some individuals were given a discount if they did not want a shirt or showed up
late.
‘Tony Lieras voluntarily appointed himself to arrange for getting T-Shirts printed.
In January of 2017, I provided Tony Lieras a list of all the people who attended Hash-A-
Thon; a list of all the people who completed alll four (4) trails; a list of all the people who
“hared” AKA laid the running trails; as well as a list of shirt sizes for all the people who
paid for a T-Shirt.
Inor around January of 2017, Amy Parker designed graphics for the Hash-A-Thon
shirt. The graphics were given to Tony Lieras.
On January 22, 2017, due to personal reasons, I did not attend the weekly run and
asked Tony Lieras to collect the weekly run fee for me. On that day, Tony Lieras did
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‘Affidavit of Constancecollect the weekly run fees. When the “Hash Cash” books (run records, weekly
accounting, and cash) were delivered to Tony Lieras, the cash on hand was
approximately $1,800. When the “Hash Cash” books were returned to me that day, the
cash on hand was approximately $1,300, Approximately $500 was missing from cash. In
addition, lasked Tony Lieras how many people attended the runand who the individuals
were in order to mark their run numbers in the books; however, Tony Lieras never told
me who or how many people attended that run. The amount of money collected and/or
reimbursed that day was never communicated to me.
Tealled and asked Tony Lieras what happened to the money. His initial response
was “I'm glad someone is paying attention.” I replied, “Yeah, that’s kinda my job.” He
then replied that he took the money for Hash-A-Thon T-Shists. I replied that we normally
get an invoice and reimburse. And, if the expense is more than an individual can put out
up front, then “Hash Cash” will pay for the expense out of the club fund bank account.
Tony Lieras explained that he had it “taken care of.” At the time, Tony Lieras was the
“GM” and I did not think that he would have any other motive for taking the money.
On March 6, 2017, I texted Tony Lieras regarding Hash-A-Thon T-Shirts
Specifically, | texted: “Question: What is the status of Hash-A-Thon shirts? -- people keep
asking me". Tony Lieras replied, “I plan on handing them out at Bat2Bar.” Bar2Bar is a
special event that is held each year in or around March, typically the weekend after St.
Patrick’s Day. He further replied, “If they don’t come I can hand them out later.” His
response implied to me that he had already ordered the shirts and he was merely waiting
for them to be finished and picked up.
2016 Hash-A-Thon shirts were not handed out at Bar2Bar 2017. In fact, to this day,
approximately two years later, 2016 Hash-A-Thon T-Shirts have not been delivered to
anyone.
Following Bar2Bar, when I would collect weekly run fees, people would
frequently ask me about the status of Hash-A-Thon T-Shirts, Given that Tony Lieras had
a working T-Shirt design and at least $500 to do a shirt order, and given that we did not
receive them at Bar2Bar, I would honestly reply: “Talk to ‘Spedo’ (AKA Tony Lieras) he’s
had the design and money since January.”
Thereafter, for reasons more apparent to me now, my relationship with Tony
Lieras quickly deteriorated and became somewhat hostile, Unless and until T-Shirts are
produced, Tony Lieras flat out stole approximately $500 from the Humpin’ Hash House
Harriers,
Affidavit of Constance Smith Page 2 0f3BEFORE ME, the undersigned authority, on this day personally appeared
Constance Smith, and being first duly sworn, and having signed the foregoing in the
capacity designated, and having read the application therein, declares that the statements
contained in this Affidavit are true and correct,
Constone Dak
Constance Smith
Affiant
SUBSCRIBED AND SWORN TO BEFORE ME on this the _/774_ day of
September —_, 2018.
(, Stale of Texas
MY COMMISSION EXPIRES
‘AUGUST 23, 2022
NOTARY ID: 131695824]
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