COMPLAINT. The Circuit Attorney of the City of St. Louis, State of Missouri, upon information and belief, charges that

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1 MISSOURI CIRCUIT COURT - TWENTY-SECOND JUDICIAL CIRCUIT (ST. LOUIS CITY) STATE OF MISSOURI VS Tenney, Maximilian C DIV #: CA#: CAUSE#: DESTINATION: GRAND JURY (AT LARGE) D E F E N D A N T I N F O R M A T I O N ADDRESS: 44XX West Pine Apt 20F Saint Louis, MO PEDIGREE: RACE: W DOB: XX/XX/1977 HGT: 5'08" SEX: M AGE: 33 WGT: 185 ID #s: COMPLAINT#: LID: ARREST#: DIST: SLMPD OCN: ALIASES: SSNs: STATE OF MISSOURI ) CITY OF ST. LOUIS ) SS COMPLAINT The Circuit Attorney of the City of St. Louis, State of Missouri, upon information and belief, charges that Count 1: Theft/stealing (value Of Property Or Services Is $25,000 Or More) (Class B FELONY) RSMo FROM 6/19/2008 TO 7/12/2010 Place: 43XX Lindell Boulevard (SCC 15018) The defendant, in violation of Section , RSMo, committed the class B felony of stealing, punishable upon conviction under Section , RSMo, in that on or between June 19, 2008 and July 12, 2010, in the City of St. Louis, State of Missouri, the defendant appropriated United States currency of a value of at least twenty-five thousand dollars, which property was in the possession of the Cathedral Basilica of St. Louis, and the defendant appropriated such property without the consent of the Cathedral Basilica of St. Louis and with the purpose to deprive it thereof. Count 2: Forgery (Class C FELONY) RSMo FROM 7/4/2010 TO 7/12/2010 Place: 2XX North Euclid Avenue (SCC 18010) punishable upon conviction under Sections and , RSMo, in that on or between July 4, 2010 and July 12, 2010, in the City of St. Louis, State of Missouri, the defendant, acting with another, with the purpose to defraud, used as genuine a writing, namely St. Louis Cathedral Choir Check number Page 1 10/25/2011

2 Count 3: Forgery (Class C FELONY) RSMo FROM 6/25/2010 TO 6/28/2010 Place: 2XX North Euclid Avenue (SCC 18010) punishable upon conviction under Sections and , RSMo, in that on or between June 25, 2010 and June 28, 2010, in the City of St. Louis, State of Missouri, the defendant, acting with another, Count 4: Forgery (Class C FELONY) RSMo ON 6/22/2010 Time: Place: 2XX North Euclid Avenue (SCC 18010) punishable upon conviction under Sections and , RSMo, in that on or about June 22, 2010, in the City of St. Louis, State of Missouri, the defendant, acting with another, with the purpose to defraud, used as genuine a writing, namely St. Louis Cathedral Choir Check number 26XX, knowing that Count 5: Forgery (Class C FELONY) RSMo FROM 6/9/2010 TO 6/10/2010 Place: 2XX North Euclid Avenue (SCC 18010) punishable upon conviction under Sections and , RSMo, in that on or between June 9, 2010 and June 10, 2010, in the City of St. Louis, State of Missouri, the defendant, acting with another, Count 6: Forgery (Class C FELONY) RSMo FROM 6/7/2010 TO 6/8/2010 Place: 2XX North Euclid Avenue (SCC 18010) punishable upon conviction under Sections and , RSMo, in that on or between June 7, 2010 and June 8, 2010, in the City of St. Louis, State of Missouri, the defendant, acting with another, Page 2 10/25/2011

3 Count 7: Forgery (Class C FELONY) RSMo FROM 5/20/2010 TO 5/21/2010 Place: 2XX North Euclid Avenue (SCC 18010) punishable upon conviction under Sections and , RSMo, in that on or between May 20, 2010 and May 21, 2010, in the City of St. Louis, State of Missouri, the defendant, acting with another, Count 8: Forgery (Class C FELONY) RSMo ON 4/28/2010 Time: Place: 2XX North Euclid Avenue (SCC 18010) punishable upon conviction under Sections and , RSMo, in that on or about April 28, 2010, in the City of St. Louis, State of Missouri, the defendant, acting with another, with the purpose to defraud, used as genuine a writing, namely St. Louis Cathedral Choir Check number 26XX, knowing that Count 9: Forgery (Class C FELONY) RSMo FROM 4/21/2010 TO 4/22/2010 Place: 2XX North Euclid Avenue (SCC 18010) punishable upon conviction under Sections and , RSMo, in that on or between April 21, 2010 and April 22, 2010, in the City of St. Louis, State of Missouri, the defendant, acting with another, Count10: Forgery (Class C FELONY) RSMo ON 3/11/2010 Time: Place: 2XX North Euclid Avenue (SCC 18010) punishable upon conviction under Sections and , RSMo, in that on or about March 11, 2010, in the City of St. Louis, State of Missouri, the defendant, acting with another, with the purpose to defraud, used as genuine a writing, namely St. Louis Cathedral Choir Check number 26XX, knowing that Page 3 10/25/2011

4 Count11: Forgery (Class C FELONY) RSMo FROM 2/11/2010 TO 2/12/2010 Place: 2XX North Euclid Avenue (SCC 18010) punishable upon conviction under Sections and , RSMo, in that on or between February 11, 2010 and February 12, 2010, in the City of St. Louis, State of Missouri, the defendant, acting with another, with the purpose to defraud, used as genuine a writing, namely St. Louis Cathedral Choir Check number 26XX, knowing that it had been made so that it purported to have been made by another. Count12: Forgery (Class C FELONY) RSMo FROM 1/31/2010 TO 2/8/2010 Place: 2XX North Euclid Avenue (SCC 18010) punishable upon conviction under Sections and , RSMo, in that on or between January 31, 2010 and February 8, 2010, in the City of St. Louis, State of Missouri, the defendant, acting with another, with the purpose to defraud, used as genuine a writing, namely St. Louis Cathedral Choir Check number Count13: Forgery (Class C FELONY) RSMo FROM 1/18/2010 TO 1/19/2010 Place: 2XX North Euclid Avenue (SCC 18010) punishable upon conviction under Sections and , RSMo, in that on or between January 18, 2010 and January 19, 2010, in the City of St. Louis, State of Missouri, the defendant, acting with another, with the purpose to defraud, used as genuine a writing, namely St. Louis Cathedral Choir Check number Count14: Forgery (Class C FELONY) RSMo FROM 11/25/2009 TO 11/27/2009 Place: 2XX North Euclid Avenue (SCC 18010) punishable upon conviction under Sections and , RSMo, in that on or between November 25, 2009 and November 27, 2009, in the City of St. Louis, State of Missouri, the defendant, acting with another, with the purpose to defraud, used as genuine a writing, namely St. Louis Cathedral Choir Check number 26XX, knowing that it had been made so that it purported to have been made by another Page 4 10/25/2011

5 Count15: Forgery (Class C FELONY) RSMo FROM 7/17/2009 TO 7/21/2009 Place: 2XX North Euclid Avenue (SCC 18010) punishable upon conviction under Sections and , RSMo, in that on or between July 17, 2009 and July 21, 2009, in the City of St. Louis, State of Missouri, the defendant, acting with another, 25XX, knowing that Count16: Forgery (Class C FELONY) RSMo ON 1/13/2009 Time: Place: 2XX North Euclid Avenue (SCC 18010) punishable upon conviction under Sections and , RSMo, in that on or about January 13, 2009, in the City of St. Louis, State of Missouri, the defendant, acting with another, with the purpose to defraud, used as genuine a writing, namely St. Louis Cathedral Choir Check number 25XX, knowing that The facts that form the basis for this information and belief are contained in the attached statement(s) of facts, made a part hereof and submitted as a basis upon which this court may find the existence of probable cause. Wherefore, the Circuit Attorney prays that an arrest warrant be issued as provided by law. Jennifer M. Joyce Circuit Attorney of the City of St. Louis, State of Missouri By Original Signed Assistant Circuit Attorney Page 5 10/25/2011

6 PROBABLE CAUSE STATEMENT DATE: October 25, 2011 I, Roger Murphey, a law enforcement officer for the City of St. Louis, State of Missouri,, knowing that false statements on this form are punishable by law, state that the facts contained herein are true. 1. I have probable cause to believe that Maximilian C Tenney, a White Male DOB: XX/XX/77 Age: 33, committed one or more criminal offense(s). Count 1: Theft/stealing (value Of Property Or Services Is $25,000 Or More) (Class B FELONY) RSMo FROM 6/19/2008 TO 7/12/2010 Place: 43XX Lindell Boulevard (SCC 15018) Count 2: Forgery (Class C FELONY) RSMo FROM 7/4/2010 TO 7/12/2010 Place: 2XX North Euclid Avenue (SCC 18010) Count 3: Forgery (Class C FELONY) RSMo FROM 6/25/2010 TO 6/28/2010 Place: 2XX North Euclid Avenue (SCC 18010) Count 4: Forgery (Class C FELONY) RSMo ON 6/22/2010 Time: Place: 2XX North Euclid Avenue (SCC 18010) Count 5: Forgery (Class C FELONY) RSMo FROM 6/9/2010 TO 6/10/2010 Place: 2XX North Euclid Avenue (SCC 18010) Count 6: Forgery (Class C FELONY) RSMo FROM 6/7/2010 TO 6/8/2010 Place: 2XX North Euclid Avenue (SCC 18010) Count 7: Forgery (Class C FELONY) RSMo FROM 5/20/2010 TO 5/21/2010 Place: 2XX North Euclid Avenue (SCC 18010) Count 8: Forgery (Class C FELONY) RSMo ON 4/28/2010 Time: Place: 2XX North Euclid Avenue (SCC 18010) Count 9: Forgery (Class C FELONY) RSMo FROM 4/21/2010 TO 4/22/2010 Place: 2XX North Euclid Avenue (SCC 18010) Count10: Forgery (Class C FELONY) RSMo ON 3/11/2010 Time: Place: 2XX North Euclid Avenue (SCC 18010) Count11: Forgery (Class C FELONY) RSMo FROM 2/11/2010 TO 2/12/2010 Place: 2XX North Euclid Avenue (SCC 18010) Count12: Forgery (Class C FELONY) RSMo FROM 1/31/2010 TO 2/8/2010 Place: 2XX North Euclid Avenue (SCC 18010) Count13: Forgery (Class C FELONY) RSMo FROM 1/18/2010 TO 1/19/2010 Place: 2XX North Euclid Avenue (SCC 18010) Count14: Forgery (Class C FELONY) RSMo FROM 11/25/2009 TO 11/27/2009 Place: 2XX North Euclid Avenue (SCC 18010) Count15: Forgery (Class C FELONY) RSMo FROM 7/17/2009 TO 7/21/2009 Place: 2XX North Euclid Avenue (SCC 18010) Count16: Forgery (Class C FELONY) RSMo ON 1/13/2009 Time: Place: 2XX North Euclid Avenue (SCC 18010) Page 1 10/25/2011

7 2. The facts supporting this belief are as follows: Maximilian Tenney worked for the St. Louis Cathedral Basilica of the Archdiocese of St. Louis. One of the operations of the Cathedral was the Cathedral Choir of the Archdiocese of St. Louis. Tenney was an executive assistant to J.R. from May, 2007, until he resigned on June 13, J.R. had oversight of the choir checking account and placed Tenney in charge of making deposits, preparing checks for payment, inputting financial information into Quickbooks logs, and reconciling the bank account. J.R. was the only individual authorized to sign checks on the account. In early July, 2010, the Internal Audit Department of the Archdiocese conducted an internal audit and found numerous disbursements from the St. Louis Cathedral Choir bank account that did not appear proper. The audit along with subsequent investigation revealed the following. Twelve checks were made payable to CJT (Calvin J. Tenney), Maximilian Tenney s father, and deposited into an account at National City Bank in the name of Calvin Tenney (hereinafter CJT account). This account was used by Maximilian Tenney and was the account used by Maximilian Tenney when he was hired by the archdiocese for the direct deposit of his payroll. These suspicious checks were all signed using J.R. signature stamp. J.R. never signed checks with this stamp or authorized others to sign checks with his stamp. Further, Tenney was the only individual with possession of this stamp, which Tenney ultimately relinquished to J.R. after Tenney s resignation. These unauthorized checks are as follows: * Check 26XX, dated January 18, 2010, for $1,638.00, was deposited into the CJT account on January 19, * Check 26XX, dated January 31, 2010, for $1,638.00, was deposited into the CJT account on February 8, * Check 26XX, dated February 11, 2010, for $1,992.00, was deposited into the CJT account on February 11, * Check 26XX, dated March 11, 2010, for $1,198.32, was deposited into the CJT account on March 11, * Check 26XX, dated April 21, 2010, for $1,410.00, was deposited into the CJT account on.april 21, * Check 26XX, dated April 28, 2010, for $1,248.00, was deposited into the CJT account on April 28, * Check 26XX, dated May 20, 2010, for $998.00, was deposited into the CJT account on May 20, * Check 26XX, dated June 7, 2010, for $802.00, was deposited into the CJT account on June 7, * Check 26XX, dated June 9, 2010, for $847.00, was deposited into the CJT account on June 9, * Check 26XX, dated June 22, 2010, for $489.00, was deposited into the CJT account on June 22, * Check 26XX, dated June 25, 2010, for $382.00, was deposited into the CJT account on June 25, * Check 26XX, dated July 4, 2010, for $625.00, was deposited into the CJT account on July 12, Six additional unauthorized checks were written. Check 25XX, dated July 17, 2009, was for $3, and made payable to Peter s Way. This was signed using the J.R. stamp and deposited into the CJT account on July 17, Check 25XX, dated January 13, 2009 for $3,988.00, was made payable to See Green (typed) with Max Teney written after the typing. J.R. signature is forged onto this check in writing. This check was deposited into the CJT account on January 13, Check 26XX, dated November 25, 2009, was for $1, and made payable to See Green. This was signed using the J.R. stamp and deposited into the CJT account on November 25, Check 25XX, totaling $4, and dated August 8, 2008, was made payable to the St. Louis Cathedral Concert Series and stamped with J.R. s signature. This check was deposited into the CJT account on August 8, Check 25XX, dated June 23, 2008 for $6,669.46, was made payable to Citi Advantage and stamped with J.R. s signature. Credit card number XXXX-XXXX was written on the front of the check, which was unendorsed. Maximilian Tenney s Citicorp credit card records confirmed this card was issued to Maximilian Tenney, and that the payment was posted on July 18, Similarly, Check 25XX for $3, dated July 16, 2008 was stamped with J.R. s signature and went to pay Maximilian Tenney s credit card bill, posting on July 18, In total, Tenney obtained at least $36, from his scheme. When confronted, Tenney indicated that he used bad judgment and would be willing to return the missing money. Tenney no longer resides in the State of Missouri. Roger Murphey PRINT NAME Original Signed SIGNATURE On April 2, 1997, Tenney pleaded guilty to misdemeanor Theft in Phoenix, Arizona. On June 23, 1999, Tenney pleaded guilty to misdemeanor Theft Obtaining Service without Paying and misdemeanor Resisting Arrest in Scottsdale, Arizona. On February 17, 2004, Tenney pleaded guilty to misdemeanor DUI- Liquor/Drugs/Vapors/Combo in Scottsdale, Arizona. On August 3, 2006, Tenney pleaded guilty to misdemeanor Extreme DUI-BAC.15 or more, False Report to Law Enforcement, and Driving with a Suspended License, and Urinating/Defecating in Public, in Scottsdale, Arizona Page 2 10/25/2011

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