BBCA Case No: 2022–TC–0474
IN THE DISTRICT COURT OF BOURBON COUNTY, KANSAS
STATE OF KANSAS, Plaintiff, )

vs.

RACHEL MAE PRUITT, Defendant.

Complaint
COMPLAINT/INFORMATION
I, Tiana M McElroy, the undersigned County Attorney of Bourbon County, Kansas, in the name and by the authority and on behalf of the State of Kansas, come here now and give the Court
to understand and be informed that:

COUNT I
COMPUTER CRIME
That on or about or between the 3rd day of July, 2019 and the 1st day of August, 2019, in Bourbon County, Kansas, one RACHEL MAE PRUITT, did unlawfully use a computer, computer system,
computer network or any other property for the purpose of devising or executing a scheme or artifice with the intent to defraud or to obtain money, property, services or any other thing of value
by means of false or fraudulent pretense or representation. In violation of 21–5839(a)(2)(b)(1), Computer Crime, a Severity Level 8 Nonperson Felony. (minimum months 7, maximum months
23) (Fine up to $100,000.00).

COUNT II
COMPUTER CRIME
That on or about or between the 3rd day of July, 2019 and the 1st day of August, 2019, in Bourbon County, Kansas, one RACHEL MAE PRUITT, did unlawfully use a computer, computer system, computer network or any other property for the purpose of devising or executing a scheme or artifice with the intent to defraud or to obtain money, property, services or any other thing of value
by means of false or fraudulent pretense or representation. In violation of 21–5839(a)(2)(b)(1),
Computer Crime, a Severity Level 8 Nonperson Felony. (minimum months 7, maximum months
23) (Fine up to $100,000.00).

COUNT III
MAKING FALSE INFORMATION
That on or about or between the 3rd day of July, 2019 and the 1st day of August, 2019, in Bourbon County, Kansas, one RACHEL MAE PRUITT, did unlawfully make, generate, distribute, draw, or
cause to be made, generated, distributed or drawn a written instrument, entry in a book of account or an electronic data entry, to–wit: a Flex Build, LLC invoice, with knowledge that such
information falsely states or represents some material matter, or is not what it purports to be, and done with the intent to defraud, to obstruct the detection of a theft or felony offense, or to induce
official action. In violation of K.S.A. 21–5824, Making False Information, a Severity Level 8
Nonperson Felony. (minimum months 7, maximum months 23).

COUNT IV
MAKING FALSE INFORMATION
That on or about or between the 3rd day of July, 2019 and the 1st day of August, 2019, in Bourbon County, Kansas, one RACHEL MAE PRUITT, did unlawfully make, generate, distribute, draw, or
cause to be made, generated, distributed or drawn a written instrument, entry in a book of account or an electronic data entry, to–wit: a Flex Build, LLC invoice, with knowledge that such
information falsely states or represents some material matter, or is not what it purports to be, and done with the intent to defraud, to obstruct the detection of a theft or felony offense, or to induce
official action. In violation of K.S.A. 21–5824, Making False Information, a Severity Level 8
Nonperson Felony. (minimum months 7, maximum months 23).

ENDORSEMENT OF WITNESSES
Officer(s): Evidence Custodian; SA Chris Farris; KBI Forensic Scientist; SA Anthony Maness;
Witness(es): Kevin Kent Allen; Susan Elizabeth Bancroft; Det. Judd Brungardt; William Lloyd Carter Jr; Major Andrew Carver; Jeffrey Deane; Rhonda Dunn;
Flexbuild; Anthony Joseph Krsnich; David Bryan Martin; Debra K McCoy; Paul Brian Wagner; Denton Jacob Wescoat;
Victim(s): City of Fort Scott;
I declare under penalty that the above and foregoing is true and correct. Executed on
Tuesday, September 6, 2022.
/s/ Tiana M McElroy
Tiana M McElroy, #21599
County Attorney
210 S National Ave., Ste. 22
Fort Scott, KS 66701
(620) 223–2910
Attorney for State.

ELECTRONICALLY FILED
2022 Sep 06 PM 3:34
CLERK OF THE BOURBON COUNTY DISTRICT COURT
CASE NUMBER: BB-2022-CR-000320
PII COMPLIANTBBCA Case No: 2022–TC–0474