6 During the summer of 2013 we the Directors and members of the Morningside

6 during the summer of 2013 we the directors and

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6. During the summer of 2013, we, the Directors and members of the Morningside Heights Booster Club, raised $150,000.00 by soliciting donations from the wealthiest residents in the District. Nevertheless, Peyton Pearson convinced us that the Booster Club should hold a fundraiser that most of the residents in the District could afford to attend. After some discussion, we, the Directors, decided to host a First Annual Morningside Heights Fun Fair, to be held from Friday, August 23, 2013 through Sunday, August 25, 2013, in nearby Shoreline Park. 7. The Fun Fair would include carnival rides for all ages, a chicken barbeque, and games of chance for adults, such as bingo, roulette and blackjack. The tickets to attend the Fun Fair would cost only $5.00 each, but we figured we’d make most of the money on the sale of tickets for the rides, the chicken BBQ and especially the proceeds from the games of chance. 8. The Fun Fair was a tremendous success. We sold over 5,000 tickets at $5.00 each, and 4,000 chicken dinners at $7.00 each. All of the revenue from the sale of the admission tickets and the chicken dinner tickets were profit because Peyton Pearson had contributed all of the food, rides and prizes, in kind. 9. Since the tickets for admission and the chicken dinners were sold at a single location, Pearson Precision’s headquarters, up until the day before the Fun Fair began, the Booster Club could easily keep track of those proceeds. This was because on every business day from the first day of sales, July 1, 2013, through Thursday, August 22, 2013, Peyton gathered the proceeds from that day’s ticket sales and personally deposited them, the very next day, in the Booster Club’s account at the local branch of the Empire of New York Bank. 10. Unlike the tickets for entry and the chicken dinners, the ride tickets were sold only during the Fun Fair. Accordingly, we could not predict how much the Booster Club would earn from the ride tickets or the games of chance. Peyton Pearson would be busy overseeing the Fun Fair during its entire three days, so s/he deputized Casey Cheatham to monitor the sales of the ride tickets and the games of chance.
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75 11/19/14 11. Peyton told Casey to gather those proceeds at the end of each day and await further instructions as to how that money was to be deposited or disbursed. A few weeks before the Fun Fair, Peyton and his/her spouse decided that they would take a three-week vacation to Europe as soon as the Fun Fair was over, from August 26, 2013 to September 16, 2013. However, before s/he left, Peyton did not give Casey any additional instructions as to what to do with the proceeds. 12. I check my Face Space daily, and while Peyton was away, I noticed, as did several other Booster Club members, that Casey had made several postings bragging about substantial personal expenditures. One of them, on September 3, 2013, said, “Take a look at my new sports car!” next to a photo of a bright red coupe. The following day, Casey posted, “Finally, I have the money to put a swimming pool in my backyard!” On September 15, 2013, Casey wrote on Face Space, “There’s
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  • Spring '17
  • mrs callman
  • attorney, new york state

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