AFFIDAVIT IN SUPPORT OF SUMMONS
STATE OF NEVADA
COUNTY OF CLARK
COLIN HAYNES, being first duly sworn, deposes and states:
I am the Affiant herein and I am a Criminal Investigator III with the State of Nevada,
Secretary of State. The agency is charged with enforcing Chapters 293 of Nevada Revised
Statutes. This chapter includes the Election Registration laws of the State of Nevada.
I have been assigned to the agency for approximately seventeen (17) months. Prior to
my employment with the agency, I was employed as an investigator with the Office of the
Attorney General for three (3) years and six (6) months, assigned to the Bureau of Consumer
Protection and Medicaid Fraud Control Unit.
Prior to my employment with the Attorney General’s Office, I worked as an investigator
with Las Vegas Metropolitan Police Department assigned to investigate Elder Financial
Exploitation for a period of five (5) years and six (6) months. I also have eleven (11) years
experience working as a police officer in London, England, assigned to patrol, field training
and intelligence divisions.
In addition to my experience investigating complex financial crimes, I have attended
NASAA investigator training courses and the Financial Investigations Practical Skills Training
hosted by the National White Collar Crime Center and Research Institute where I learned
investigative skills pertaining to Securities Fraud and other financial crimes. In 2004 I
successfully completed the requirements for Peace Officer Category II Basic Certification,
which included 276 hours of instruction. I also have the Intermediate and Advanced Peace
Officer certificates from the State of Nevada and I am a Certified Fraud Examiner through the
national Association of Certified Fraud Examiners.
On July 2 2008, I was assigned to investigate a referral regarding a series of apparently