(R-10aa6-34 CITY COURT OF THE CITY OF WHITE PLAINS COUNTY OF WESTCHESTER THE PEOPLE OF THE STATE OF NEW YORK FELONY COMPLAINT DAMON DAVIS CHARLENE HUMPHREYS. Defendant [BE IT KNOWN thatthe complainant herein: Steven Sassone, an Investigator with the Westchester County District Atomey’s Office ("WCDAO"), accuses the defendants, Damon Davis and Charlene Humphreys, ofthe following offenses) committed in the City of White Plain, from on ‘or about and between March 16, 023, and April 11,2023, as specified below. COUNTS ONE AND TWO: The Offense of FALSIFYING BUSINESS RECORDS IN THE FIRST DEGREE, a violation of Penal Law 175.10(1) EFI. “The defendants, atthe below-specifed dates and locations, while acting in concert, did commit the ime of falsifying business records in the second degree, andthe defendants intent o defraud included an intent to commit another erme o to ad o¢ conceal the commission thereof Background of Investigation |. This complaint and sllegations of fact contained herein are based on my direct knowledge ‘and upon information and belief, with the sources of information and the grounds for belief being a WCDAO investigation that included, but was not limited 1, my review of records and other materials obtained during the course of the investigation as well a informati provided to me by the Westchester County Clesk (“WCC”) and witnesses with knowledge of this investigation. have not included every fact known to me concerning this investigation. Rather, I have set forth only those facts that I believe are sufficient to establish the necessary Foundation for this complaint. 2. During the dates referenced in this complaint, specifically from on of about and between March 16, 2023, and April 11, 2023, defendant Davis was a licensed notary public with the State of New York, commissioned in Westchester County." * am also aware ht during the des referenced in his compli, the defendets were employed by the Cy of Mode Vernon Deparinet of Buildings Code Enlorcement Office3. The WCC, specifically the WCC Land Records Division, located at 110 Dr. Matin Luther King J. Boulevard in White Plans, New Yor, is responsible for receiving and recording documents pertaining to real property transactions occuring in Westchester County. The WCC Property Records Electronic Portal system (“PREP”) is used by the WCC to accep, review, and approve submissions forthe transfer of property in Westchester 4. 1am informed by Margaret Crawford, WCC Land Records Division Program Coordinator, ‘that the submission process isa follows: 1. Initial information-—including party names, propery detils, and type of land record submission is provided to the WCC electronically, using PREP. Individuals wishing to submit information to the WCC twough PREP are fist required to create a PREP user account. '. The information entered by a user in PREP automatically populates the forms required forthe transfer, which, after ll required data is extered, are avaiable to be printed from PREP. The completed, signed documents ae then submitted tothe ‘WCC in hard copy, either by mail orn person? Hard copy packages submitted to the WCC for fling must include a cover page created using PREP. Any requisite tax forms related to the particular property transfer must also be created using PREP. {€. Once all ofthe information and records are submitted tothe WCC relating to a particular property transfer, the WCC reviews the records tc determine whether the property transfer documents should be recorded. The WCC compares the information submitted electronically in PREP with the hard copy documents ‘make sue thatthe electronic enries match the entries onthe documents. Once the [WCC determines that the package is complete and accurate, and the WCC Finance Department confirms that the property submission fees have been paid by the submitter, the land transfer documents are approved and recorded by the WCC. 5. Tam aware, based on my review of WCC PREP user account rears, that @ PREP user account was created on March 16, 2023, with User ID “Business! 01.” The "Business101” account was subsequently used to create two packages in PREP relating to two separate ‘Mount Vernon, New York property transactions, described in furher detail below. The ser information associated with “Business|” inluded the names “Jennifer Blaine” and “Jennifer Humphreys"; telephone number ending "7846"; telephone number ending, 2307 and associated email address Jenifer_1015S@yahoo com. 5 Upon appeval by exccuting the "Westcheser County Registered Submit Apreemex,” approved PREP users "othnve to submit dscumen’in bard opy fom and may electronical file and wns ocurents with the WCC. ‘cording 1 te WCC, ano time wae wer "BstesI01", eased Fuhr inpraagh 5,4 Wet approved 1 ‘eewoncally le decuments wih he WCC.4 I know, based on my review of law enforcement database searches, that defendant Humphreys" middle name is “Jennifer” and am further informed by financial records obtained durin the course ofthis investigation, that defendant Humphreys" ‘mother's maiden name is “Blaine” '. know, from my review of records fom telecommunication providers obtained in connection with this investigation, that telephone numbers ending in 7846 and 2307 are associated wth defendant Humpheeys. Lam further aware, based on my review of records obtained from Yahoo In. during the course ofthis investigation, thatthe subscriber name for email address “Jennifer [email protected]” is. “char hhumphreys" and the associated recovery telephone number is the above-referenced, telephone number ending in 7246, COUNT ONE, ‘352 Summit Avenue, Mount Vernon, New Ye (On or about March 16,2023, defendant Humphreys, using PREP User ID “Business101," electronically entered dat into PREP relating to the transfer of 352 Summit Avenue, ‘Mount Vernon, New York; the package was assigned Control Number 630753612. Requisite supporting documents were automatically created by the WCC PREP system based on the information entered by defendant Humphreys, including the PREP cover sheet, an RP.S217 Real Property Transfer Tax Report (“RP-5217"), and a TP-S84 ‘Combined Real Estate Transfer Tax Retum form (“TP-$84") ‘On or about March 27, 2023, a quit claim deed and the required supporting documents referenced in paragraph 6 above, were filed in hard copy form with the WCC ("252 Summit package”) forthe transfer of 352 Summit Avenue. Ihave reviewed these records. The deed was purportedly executed by an individual known to the WCDAO (hereinafter, “Individual-1") and included a "Notary Acknowledgement” completed by defendant Davis stating that Individual “personally appeared” and was either “personally known to [defendant Davis} or proved on the basis of satisfactory evidence to be the person” who personally appeared, Tinow, based on my review ofthe 352 Summit package, that the RP-5217, created in PREP. based on defendant Eumphreys’ entries, referenced in paragraph 6 above, specified that the sale of property was a “sale between relatives or former relatives” and appears to have ‘been signed by Individual-1 asthe seller on March 1, 2023. ‘The 352 Summit package also included a TP-S84 that specified thatthe sale of property ‘was a "Conveyance vhich consists ofa mere change of identity or form of ownership or10. coxganization” and appears to have been signed by Individual-! as the grantor on March I, 2073. {1am informed by ndividul-1 that he had no knowledge of, and dd nt sign, the documents inthe 352 Summit package, including, specifically, the deed. ‘know, based on my review of WCC reconds related to PREP Control Number 630753612, that the deed was recorded by the WCC on April 5, 2023. counr Two 10 Madison Strect, Mount Vernon, New. ‘On or about March 24,2023, defendant Humphreys, using PREP User ID "Business101,” electronically entered data into PREP relating to the transfer of 10 Madison Street, Mount ‘Vernon, New York; the package was assigned Control Number 630843009. Requisite supporting documents were automatically created by the WCC PREP system besed on the information entered ty defendant Humphreys, including the PREP cover sheet, an RP. 5217, and a TP-S84, (On or about April 10, 2023, a quit claim deed and the required supporting documents referenced in paragraph 12 above, were filed in hard copy form with the WCC ("10 Madison package”) fer the transfer of 10 Madison Street. I have reviewed these records. ‘The deed was purportedly executed by a deceased individual (hereinafter, “Deceased- 1"), ‘The deed included a "Notary Acknowledgement” completed by defendant Davi stating ‘that Deceased-I “peronally appeared and was either “personally known to (defendant Davis} or proved on the basis of satisfactory evidence to be the person” who personally appeared ‘now, based on my review ofthe 10 Madison packegs, het the RP-S217, rated in PREP based on defendant Humphrey’ ens, ference in paragraph 12 above, specified that the sale of property was a “sale between relatives or former relatives” and appears to have been signe by Deceed- a th llr on March 1, 2023, ‘The 10 Madison package also included a TP-S84 thet specified thatthe sale of property ‘was a "Conveyance which consists of a mere change of identity or form of ownership or “organization” and appears to have been signed by Deceased-1 asthe grantor on March 1, 2023, | know, based on my review of New York State Department of Health ("NYS DOH”) ‘ertficates of death obtsined during the course of this investigation, that Deceased-1 passed away on January 9, 2018.17. Lnow, based on my review of WCC records related to PREP Control Number 630843009, thatthe deed was recorded by the WCC on April 11, 2023, NOTICE: PURSUANT TO THE PENAL LAW §210.45, IT IS A CRIME PUNISHABLE AS. ‘A CLASS A MISDEMEANOR TO KNOWINGLY MAKE A FALSE STATEMENT HEREIN. December 18, 2028 SNV Winer hennonc®S34 Tvestgator Steven Sessone