Report on the Forensic Analysis of The Kingman Airport Authority November 2018 Table of Contents Page Background and Assignment 1 Discussion of Analysis 2 Conclusion 8 Signature 9 Schedule of Land Trust Obligation Footnote Date (1996-2010) Schedule 1 Schedule of Land Sale Footnote to GL Reconciliation Schedule 2 Schedule of Payments – Spencer Fane Schedule 3 Schedule of Payments – Bruno Brooks & Goldberg PC Schedule 4 Schedule of Payments – David French Schedule 5 Schedule of Legal Payments Analysis – July 1, 2016-May 10, 2018 Schedule 6 Pivot Table – Summary of all Transactions by Year (Mohave State Bank Checking) Schedule 7 Summary Schedule of Payments by Recipient – 2007 Schedule 8 Summary Schedule of Payroll by Recipient – 2007 Schedule 9 Schedule of Transaction Detail – 2007 Schedule 10 Summary Schedule of Payments by Recipient – 2008 Schedule 11 Summary Schedule of Payroll by Recipient – 2008 Schedule 12 Schedule of Transaction Detail – 2008 Schedule 13 Summary Schedule of Payments by Recipient – 2009 Schedule 14 Summary Schedule of Payroll by Recipient – 2009 Schedule 15 Schedule of Transaction Detail – 2009 Schedule 16 Summary Schedule of Payments by Recipient – 2010 Schedule 17 Summary Schedule of Payroll by Recipient – 2010 Schedule 18 Schedule of Transaction Detail – 2010 Schedule 19 Table of Contents (Continued) Page Summary Schedule of Payments by Recipient – 2011 Schedule 20 Summary Schedule of Payroll by Recipient – 2011 Schedule 21 Schedule of Transaction Detail – 2011 Schedule 22 Summary Schedule of Payments by Recipient – 2012 Schedule 23 Summary Schedule of Payroll by Recipient – 2012 Schedule 24 Schedule of Transaction Detail – 2012 Schedule 25 Summary Schedule of Payments by Recipient – 2013 Schedule 26 Summary Schedule of Payroll by Recipient – 2013 Schedule 27 Schedule of Transaction Detail – 2013 Schedule 28 Summary Schedule of Payments by Recipient – 2014 Schedule 29 Summary Schedule of Payroll by Recipient – 2014 Schedule 30 Schedule of Transaction Detail – 2014 Schedule 31 Summary Schedule of Payments by Recipient – 2015 Schedule 32 Summary Schedule of Payroll by Recipient – 2015 Schedule 33 Schedule of Transaction Detail – 2015 Schedule 34 Summary Schedule of Payments by Recipient – 2016 Schedule 35 Summary Schedule of Payroll by Recipient – 2016 Schedule 36 Schedule of Transaction Detail – 2016 Schedule 37 Summary Schedule of Payments by Recipient – 2017 Schedule 38 Summary Schedule of Payroll by Recipient – 2017 Schedule 39 Schedule of Transaction Detail – 2017 Schedule 40 Summary Schedule of Payments by Recipient – 2018 Schedule 41 Summary Schedule of Payroll by Recipient – 2018 Schedule 42 Schedule of Transaction Detail – 2018 Schedule 43 Table of Contents (Continued) Page Benford’s Law Testing Schedule 44 Pivot Table – “Sevens” Digit Schedule 45 Schedule of “Sevens” Digit Transaction Detail Schedule 46 Pivot Table – “Eights” Digit Schedule 47 Schedule of “Eights” Digit Transaction Detail Schedule 48 Kingman Airport Authority, Inc. Trust Fund Obligation Spreadsheet Exhibit 1 Background and Assignment In December 2017, the City of Kingman (“Kingman”) filed a complaint in Arizona Superior Court, County of Mohave, seeking a judgment to condemn certain “real and personal property being used for the operation of the Kingman Airport, including the associated industrial park…” under the control of the Kingman Airport Authority (“KAA”) prior to Kingman’s effort to condemn the property (the “Condemnation Action”).1 The Court rendered its final opinion in the Condemnation Action in May 2018, at which point Kingman took over operation of the Kingman Airport (the “Eviction”). In August 2018, Kingman filed a complaint in Arizona Superior Court, County of Mohave, against certain former members of management of KAA, the Board of Directors of KAA, and law firms representing KAA, primarily alleging the misuse of certain monies under the control of KAA (the “August 2018 Complaint”).2 A primary motivation for both the Condemnation Action, and the subsequent August 2018 Complaint, centered on the use of certain airport funds “obtained from the sale of excess land at the airport – industrial park property – be used for improvement of the airport” (the “FAA Requirement”).3 Most notably, it is our understanding that the combination of public complaints and political inquiry as to KAA management’s alleged adherence to the requirement to use land sales proceeds specifically for the improvement of the airport ultimately led to the Condemnation Action. We were assigned to analyze the accounting records of KAA to identify the use of funds for the time period over which records were available, provide insight into the general state of the records at KAA, assemble data on payments to certain defendants identified in the August 2018 Complaint, and perform limited procedures to evaluate the likelihood of potential misappropriation of funds. It should be noted that our procedures were designed only to answer limited questions regarding the substance of certain transactions which occurred between during the time period over which records were available, and were not specifically designed to conform with Generally Accepted Auditing Standards (“GAAS”) or Generally Accepted Government Audit Standards (“GAGAS”). Consequently, our procedures should not be construed as audit procedures for the purpose of rendering opinions on the financial statements of Kingman or KAA on the whole, or for compliance with any grant or other funding requirements. Nevertheless, should Kingman’s auditors request, we are willing to share our results with them for their review and analysis in connection with their audit procedures. 1 See Complaint in Eminent Domain, CV2017-00965, dated December 4, 2017, pgs. 1-3. 2 See First Amended Complaint, S8015CV2018-00781, dated August 27, 2018, pgs. 1-6. 3 Ibid., pg. 3. 1 Throughout the course of performing our assignment we were provided: 1) the full cooperation of current Kingman and KAA employees; and 2), unrestricted access to all available documentation, records, and personnel. Discussion of Analysis We were provided unrestricted access to the offices, facilities, and records held-on site at the Kingman Airport. Additionally, we were provided access to the computer files maintained by a former KAA employee – Brenda Chastain – who had primary responsibility for the accounting for KAA. Records The primary records included in our analyses were in the form of the electronic Sage/Peachtree accounting file. Upon initial inspection, it was determined that this electronic file included transactions and balances which spanned from January 2007 through the Eviction in May 2018 and represented the entirety of the general ledger accounting record for KAA for that time period. We inquired as to the location of the general ledger records for KAA which preceded January 2007, but neither current KAA staff nor City of Kingman personnel were able to locate those records in any form. This was the first of several concerning symptoms regarding the general condition of the record keeping at KAA prior to the Condemnation Action. Hard copy records in support of ordinary operating expenses were maintained in a generally orderly fashion with all invoice, payment approval and check documentation filed together by vendor and year. Although we did not perform detailed audit procedures on these transactions, inspection of the electronic records appeared to indicate these more mundane transactions were recorded in an orderly and reasonable fashion as well. We were also allowed to inspect the contents of the computer of Ms. Brenda Chastain. It is our understanding that Ms. Chastain had primary responsibility for maintaining the books and records of KAA. In reviewing her computer, we noted documents appeared to be organized into a variety of folders. However, inspection of the contents of those folders revealed a significant amount of co-mingling of documents into seemingly unrelated folders. Additionally, we noted the presence of a significant amount of records related to Ms. Chastain’s personal work with certain youth sports leagues. FAA Requirement Records A primary concern leading to the Condemnation Action was the use of funds, especially with regard to capital projects and compliance with the FAA Requirement. The FAA Requirement specifically mandates that the proceeds from land sales in the area surrounding the Kingman Airport are to be spent: 2 “…within Five (5) Years of each sale of parcel of land sold…, any excess funds upon items within the following priority categories, and it is further provided that all currently needed development within the highest priority category must be accomplished before improvements in the next category are begun (emphasis added). “A. Approved items of airport development set forth in FAR Part 152 (and as appropriate, set forth in the NASP by priority of need) to be accomplished in accordance with currently applicable FAA design criteria. “B. Any aeronautical items of airport development ineligible for direct Federal aid under Airport Development Aid Program. “C. Deposit to the airport fund for deferred use within a reasonable time for items A and B above. “D. Retirement of airport bonds which are secured by pledges of airport revenue. Includes repayment of loans from other Federal agencies for such development. “E. Development of common use facilities and utilities of the dedicated revenue production property of the airport now owned or subsequently acquired. “F. Current expenses for repair, maintenance