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IN THE UNITED STATES DISTRICT COURT FOR THE

DISTRICT OF COLUMBIA
In Re: Arrest Warrant for
Andrea Elaine Turk

Federal Bureau of Investigation

Washington Field Office
Northern Virginia Resident Agency
9325 Discovery Boulevard
Manassas, Virginia 20109

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Case No. _______________

Under Seal

AFFIDAVIT IN SUPPORT OF CRIMINAL COMPLAINT AND APPLICATION FOR

ARREST WARRANT FOR ANDREA ELAINE TURK
I, Martin F. Harris, being duly sworn, do hereby depose and state as follows:
Background of Affiant
1.

I am a Special Agent of the Federal Bureau of Investigation (FBI) and have

been so employed since September 1994. I am currently assigned to the Washington Field
Office, Northern Virginia Resident Agency, in Manassas, Virginia. Since becoming an FBI
agent, I have conducted numerous investigations of federal criminal offenses, including matters
involving public corruption and government contract fraud. I have received specialized training
in this area, both during my initial training at the FBI Academy and through periodic training
seminars and conferences.
Purpose of Affidavit
2.

This affidavit is submitted in support of a criminal complaint and an application

for the issuance of an arrest warrant for ANDREA ELAINE TURK (TURK). This affidavit is
based on my personal knowledge, as well as information obtained from other law enforcement
officers and personnel, witnesses, documents, and records. I am familiar with the facts set forth
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in this affidavit based upon my participation in this investigation, communications with other
agents, officers, and law enforcement personnel, my review of records and documents obtained
during the course of the investigation, and information gained through training and experience.
Because this affidavit is being submitted for the limited purpose of setting forth probable cause, I
have not included every fact known to me concerning this investigation. I have set forth only the
facts that I believe are necessary to establish probable cause to charge TURK with Theft of
Government Property, in violation of Title 18, United States Code, Section 641.
Probable Cause
3.

In September 2013, law enforcement received a criminal referral from the Office

of Counsel to the President, The White House, Washington, D.C., alleging that TURK, a former
employee, had falsified timekeeping records for the purpose of obtaining money to which she
was not entitled. Specifically, the referral alleged that TURK unlawfully inflated the number of
overtime hours worked by Employee A, a subordinate to TURK, causing overtime payments to
be made to Employee A, who in turn, at TURKs direction, transferred money back to TURK.
Following discovery of the misconduct, TURKs employment was terminated in August 2013.
4.

As part of the investigation into this matter, your affiant learned that TURK was

employed as the Director of Information Services at The White House, Executive Office
Building, from October 2009, until her termination in August 2013.

As the Director of

Switchboard Operations, TURK was responsible for managing approximately 15 switchboard

operators who worked at the White House. Her duties and responsibilities included oversight of
daily work schedules and the final entry and approval of all time and attendance records,
including overtime, for each of the switchboard operators, including Employee A.
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relevant times, the White House, Executive Office Building was an agency of the United States,
located in the District of Columbia.
5.

Your affiant interviewed Employee A, who advised that she began working as a

switchboard operator for the White House in May 2011. Employee A reported to TURK as her
immediate supervisor until approximately March 2012, when TURK was promoted to the
position of Director of White House Services, after which TURK maintained oversight of
Switchboard Operations and other areas at the White House, Executive Office Building.
6.

According to Employee A, in approximately early 2012, while TURK was

Employee As immediate supervisor, TURK called Employee A into TURKs office for a private
meeting, during which TURK discussed personal financial difficulties that TURK was
experiencing. TURK told Employee A that she had bills to pay and stated, Im going to need
help. During that meeting, TURK did not specify the kind of help she would need from
Employee A.
7.

Employee A explained that, after TURK was promoted to Director of White

House Services, TURK became very aggressive in requesting personal favors and assistance
from Employee A with respect to TURKs financial problems. On a particular occasion, TURK
called Employee A, stated that she (TURK) put extra overtime hours on Employee As
paycheck, and instructed, I'm going to need that out, or words to that effect. Employee A
understood from TURKs comments that TURK put extra overtime hours on Employee As time
and attendance records and was expecting Employee A to pay the additional money back to
TURK. Employee A initially responded that she did not want to assist TURK in this manner and
suggested that TURK seek financial assistance or ask for a loan. When Employee A also
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expressed concern that she and TURK would be discovered and get into serious trouble, TURK
replied that the Human Resources department did not pay attention to such issues and would
never discover their conduct. According to Employee A, TURK was very aggressive and
persistent in pressuring Employee A to agree to do as TURK instructed.
8.

Following this conversation, Employee A received significant increases in the

amount of overtime pay on her paycheck for overtime hours that she did not actually
work. Employee A estimated that this inflation of overtime hours occurred numerous times,
covering approximately 10-20 pay periods beginning in early- to mid-2012 through mid-2013.
After receiving overtime payments for inflated overtime hours that had not actually been worked,
Employee A paid a portion of the unearned overtime funds back to TURK, ranging in amount
from $100 to $600 on each occasion. Employee A made the first payment to TURK in cash.
Following the initial cash payment, TURK requested that Employee A make future payments via
online wire transfers, directly from Employee As bank account to TURKs bank account.
TURK provided Employee A with her bank account information to enable Employee A to
complete future payments via wire transfers. The amount of money paid by Employee A to
TURK varied, depending on the amount of overtime hours that TURK added to Employee As
time and attendance record. On a few occasions, TURK advised Employee A that Employee A
had not paid TURK enough money and stated further, I need more, after which Employee A
paid TURK an additional amount of money.
9.

During an interview with your affiant, TURK stated that she had been

experiencing financial difficulties and, as a result, borrowed money from Employee A. When
TURK was unable to repay the money loaned to her by Employee A, however, TURK altered
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Employee As previously recorded legitimate time and attendance records, to reflect additional,
illegitimate overtime hours that Employee A did not actually work. TURK explained that this
allowed TURK to repay Employee A, rewarded Employee A for helping TURK with her
financial difficulties, and allowed Employee A to continue to have extra money that Employee
A, in turn, could give to TURK.
10.

According to TURK, the first time that she added unearned overtime hours to

Employee As time and attendance record, Employee A paid TURK approximately $200 in cash
for the extra, unearned, overtime hours. Employee A subsequently agreed to regularly receive
payments for the additional overtime hours added by TURK on Employee As paycheck that
were not actually worked by Employee A. TURK also explained that, following the initial
payment, she and Employee A discovered that they both maintained accounts at the same bank,
after which TURK decided that it would be easier and quicker for Employee A to wire transfer
the money directly from Employee As bank account to TURKS bank account.
11.

TURK admitted that she repeatedly added significant overtime hours to Employee

As time and attendance for overtime hours that Employee A had not worked. When Employee
A received the additional payments for the overtime hours in Employee As paycheck, Employee
A wire transferred a portion of the additional money into TURKs bank account, usually ranging
between $100 and $400 each time. According to TURK, she and Employee A did not have a
formal agreement regarding how much Employee A would keep and how much Employee A
would transfer to TURK. Additionally, TURK stated that she did not provide Employee A with
the amount to be transferred to TURK on each occasion. TURK admitted that both she and

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Employee A knew that it was wrong and illegal to add or accept overtime hours that were not
actually worked.
12.

During the interview, TURK also stated that Employee A not only worked as a

switchboard operator, but also took on other duties such as helping TURK with administrative
functions, training, policies, special events, and community service. TURK added that, at times,
she associated with Employee A outside of the workplace and that TURK considered herself and
her children as a substitute family for Employee A, who assisted TURK with certain family
matters, such as babysitting, picking up TURKs child from daycare, and assisting when TURK
experienced car trouble.
13.

Although Employee A acknowledged having some contacts with TURK outside

of work, Employee A stated that the relationship with TURK was primarily a professional one
and that Employee A did not consider her relationship with TURK to have been personal or
social in nature. Employee A added that, at times, TURK made Employee A feel obligated to
interact outside of work with TURK, including performing personal favors, such as babysitting
and picking up TURKs child from daycare.
14.

A review of The White House, Executive Office Building time and attendance

records, to include TSA Weekly Reports and a Premium Hours and Pay report regarding
Employee A, revealed that, between on or about the pay period ending June 2, 2012, and on or
about the pay period ending July 27, 2013, Employee A was paid approximately $12,475.81 for
396 overtime hours, but only appears to have actually worked, recorded, and legitimately earned
less than approximately 50 overtime hours for the same time period.

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15.

A review of bank records for TURK and Employee A, identified approximately

$4,815 in bank wire transfer payments received by TURK from Employee A between June 2012
and July 2013.
Conclusion
16.

Based on the information contained in this affidavit, I believe there is probable

cause to believe that TURK engaged in Theft of Government Property, in violation of Title 18,
United States Code, Section 641.
Accordingly, your affiant respectfully requests the issuance of an arrest warrant for
TURK, based on her violation of Title 18, United States Code, Section 641.

________________________________
MARTIN F. HARRIS
Special Agent
Federal Bureau of Investigation

Subscribed and sworn before me this ____ day of October, 2015.

________________________________
MICHAEL HARVEY
UNITED STATES MAGISTRATE JUDGE