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November 7, 2017: Nicole Smith, Statement of Facts in Support of Guilty Plea


The following are the facts in support of the guilty plea for STATE V. NICOLE M. SMITH in CASE NO.: C-02-CR-17-001261.

On January 7, 2016, the Historic Inns of Annapolis held a breakfast fundraiser for Delegate Sally Jameson of Charles County. This fundraiser was paid for by the Friends of Sally Jameson campaign finance committee via a check written in the amount of $1,345.86. The check was check number 1232. At that time, the Defendant, Nicole Monique Smith, was employed as the Night Auditor for Historic Inns and was responsible for reviewing the daily receipts as well as posting charges to customer “folios” from the day.

Although it was not usual business practice, a copy of the check written by Delegate Jameson to Historic Inns for hosting the fundraiser was included on the receipt from January 7, 2016. As the Night Auditor on the evening of January 7, 2016, the Defendant had access to this receipt. Using the bank account information provided, the Defendant willfully and knowingly exerted unauthorized control over the campaign committee’s funds for her personal use and benefit.

Pursuant to one scheme and continuing course of conduct, between January 7, 2016 and October 26, 2016, in Anne Arundel County, Maryland, the Defendant knowingly, willfully, and intentionally made approximately forty-three (43) unauthorized electronic withdrawals of campaign funds from the Friends of Sally Jameson campaign finance committee. The total theft amounted to $10,806.38.

This activity persisted until October 25, 2016, when Delegate Jameson became aware of the unauthorized payments and contacted the Maryland State Board of Elections. Subsequently on November 9, 2016, the Maryland State Board of Elections referred the matter to the Officer of the State Prosecutor to conduct an investigation into the theft of campaign funds.

An extensive investigation, which included analysis of the bank account registered to the Friends of Sally Jameson, revealed that the Defendant using the bank account associated with the Friends of Sally Jameson made internet payments on personal accounts registered to Nicole Smith. Specifically, a review of the PNC bank records showed electronic payments deducted from the checking account associated with Friends of Sally Jameson.

Evidence obtained during the investigation revealed that payments in the amount of $4,682.66 were made to a Walmart credit card and $1,403.28 to Comenity Bank for a Lane Bryant retail account. It was further determined that the Sally Jameson campaign finance account was used to make three payments on a Toyota Motor Credit Company account for the personal vehicle held by Nicole Smith for a total of $987.00. The Defendant also made payments on a Credit One bank card using the checking account associated with the Friends of Sally Jameson in the amounts of ​$1,737.02 and $1,243.18. The evidence also showed expenditures were not only through web payments but an electronic check was issued to Capital One. On or about March 18, 2016, a payment of $455.05 was applied from the Sally Jameson account to a Capital One credit card in the name of Nicole Berry.

In addition to and as a part of the continuing nature of the theft, the Defendant knowingly and willfully assumed the identity of another with the fraudulent intent to get a benefit, credit, good, service, or other thing of value. By using the personal identifying information without consent, the Defendant applied for and opened three (3) credits cards – Credit One, Lane Bryant d.b.a. Comenity Bank, and Walmart in the name of another, to make approximately $7,346.56 in personal purchases.

When confronted by investigators from the Office of the State Prosecutor on May 11, 2017, the Defendant admitted to using the campaign finance committee’s funds for payment of her personal credit card bills, including Credit One, Capital One, Walmart, Comenity Bank, and Toyota Motor Credit Company.

If called to testify, a representative from the Friends of Sally Jameson campaign finance committee would identify the Defendant Nicole Smith, as the woman sitting at trial table with counsel and that neither permission nor authorization had ever been given to the Defendant to transfer or use the campaign funds for her personal expenses and benefit.

All of these events occurred in the State of Maryland.