Organized Retail Crime unit files new criminal prosecution against three defendants

New case allegedly involves “double dipping” scheme — using previous receipts to steal duplicate items

EVERETT — Attorney General Bob Ferguson’s Organized Retail Crime Unit has filed felony criminal charges against three people. This is the sixth prosecution since Ferguson established the unit last year.

The Attorney General’s Office charged Volodymyr Tsuman and Leonid Trotskovets with first-degree organized retail theft, and Volodymyr’s brother Veniamen Tsuman with second-degree organized retail theft in Snohomish County Superior Court. The Attorney General’s Office alleges they stole at least $48,878 worth of merchandise during more than 50 separate thefts in four different counties.

The affidavits of probable cause for Volodymyr Tsuman, Veniamen Tsuman and Trotskovets assert the three engaged in a “double-dipping” scheme where they purchased flooring and home improvement products for their business from Home Depots in Snohomish, Thurston, Pierce and King counties, then went back into the stores with the receipts to steal additional merchandise matching their original purchase. If questioned, they would show the receipt from the original purchase to get out of the store with the unpaid merchandise. In other thefts, they also used pick-up paperwork from one store to steal the same or similar merchandise from another, or failed to scan merchandise at self-checkout stands.

If convicted, Volodymyr Tsuman and Trotskovets each face a maximum of 10 years in prison and $20,000 in fines. Veniamen Tsuman faces a maximum of 5 years and $10,000 in fines. The Attorney General’s Office will also seek full restitution for Home Depot.

Organized Retail Crime Unit Assistant Attorney General Katie Thomason, senior investigators Matthew Harschfeld and Jerry Lerum, and paralegals Teri Chase, Abigail George and Freyja Vining are handling the case for Washington.

The affidavit of probable cause filed with the court today is provided in its entirety below. The details contained in the affidavit of probable cause are only allegations. A person is presumed innocent unless and until the individual is proven guilty beyond a reasonable doubt in a court of law.   

The Attorney General’s Office does not have authority to initiate criminal prosecutions, unless it receives and accepts a referral from a county prosecutor or the governor. For this case, the Attorney General’s Office accepted referrals from Snohomish, Thurston, Pierce and King counties.

The Rules of Professional Conduct govern what a prosecutor in a criminal case may say publicly before trial. As the prosecutor in this criminal matter, the Attorney General’s Office and its representatives are prohibited from making public statements beyond the narrow scope allowed by the Rules of Professional Conduct. The office will make every effort to be transparent with the public, while upholding its responsibilities as a criminal prosecutor.

Organized Retail Crime Unit created to offer centralized resources

Ferguson created a central Organized Retail Crime Unit in 2023. The need for a centralized unit and more investigative and prosecutorial resources was identified by Ferguson’s Organized Retail Crime Task Force, which he convened in 2022. The task force includes representatives from state, local and federal law enforcement, small and large businesses, and retail workers.

“Organized retail thieves can be brazen and prolific,” Ferguson said. “Organized retail crime is a sophisticated problem and our Organized Retail Crime Unit is an equally sophisticated team. We will do everything we can to protect hardworking Washington business owners.”

Organized retail crime involves a group of individuals that steal products in order to resell them for a profit. This does not include petty theft, shoplifting or poverty-driven crimes. Organized retail crime differs from burglary and larceny — such as shoplifting — in that it is not the result of a single individual breaking the law, but rather part of an organized scheme to defraud retailers or to steal products for resale elsewhere. Organized crime can result in intimidation and violence for employees in those stores.

The Organized Retail Crime Unit is available to assist with investigations — including coordinating them across multiple jurisdictions — and deploy resources where they are most needed. The unit can prosecute cases referred to the office by county prosecutors.

Ferguson’s Organized Retail Crime Unit secured its first conviction in June.

Nine other states have a task force dedicated to organized retail crime. Multiple states recently established similar units in their state attorney general’s office, including Arizona and Michigan.

Washington’s 10-person unit has two prosecutors and four investigators, in addition to paralegals and a data analyst. Assistant Attorney General Kent Liu, a criminal prosecutor who has worked for the office for more than 15 years, leads the unit.

Affidavit of Probable Cause

I, Matt Harschfeld, declare under penalty of perjury:

I am a Senior Investigator for the Washington State Attorney General’s Office Criminal Justice Division, Organized Retail Crime Unit. I am familiar with the police reports, loss prevention reports, photo stills, investigative materials and videos provided by The Home Depot, detailing the alleged thefts by Volodymyr Tsuman, Veniamin Tsuman and Leonid Trotskovets at The Home Depot in King, Pierce, Snohomish and Thurston counties in Washington State from April 2024 through July 2024.

My findings, described below, provide probable cause to charge Volodymyr Tsuman with one count of Organized Retail Theft 1st Degree, Veniamin Tsuman with one count of Organized Retail Theft 2nd Degree, and Leonid Trotskovets with one count of Organized Retail Theft 1st Degree, stemming from the 54 separate theft incidents totaling a loss of $48,878.47.

Training and Experience

Your affiant, Matt Harschfeld, has been employed as a Senior Investigator for the Attorney General’s Office (AGO) since July 12, 2024. I am currently assigned to the Organized Retail Crime Unit, conducting criminal investigations into all facets of Organized Retail Crime. In 1992 I earned two degrees from Green River Community College, an Associates in Arts and a Pre-Professional Business degree. I was employed by the Washington State Patrol from January 1998 until my retirement in June 2024. My assignments during my career included uniformed patrol, field training officer, academy instructor, Auto Theft detective, and SWAT operator. During those assignments I conducted basic criminal investigations, felony collision investigations and large-scale auto theft investigations. In 2019 I was promoted to Sergeant where I supervised an executive protection unit, a uniformed patrol detachment and a detective unit. During my career I was a part of planning and executing hundreds of operations to include surveillance, under cover and tactical missions. I have received extensive training in criminal investigations from state and federal agencies including the Washington State Patrol, Washington State Criminal Justice Training Commission, DEA, and Homeland Security.

Investigation Background

The AGO convened an Organized Retail Crime Task Force to address the ongoing proliferation of retail theft related crimes. The Home Depot, a national home improvement chain that sells building materials, tools, household and garden supplies, and appliances under the store banner The Home Depot, is a participant in the AGO Task Force. The Home Depot has gathered information on serial offenders Volodymyr Tsuman and Veniamin Tsuman, along with accomplices, who have made a significant financial impact to store losses. The Home Depot initially indicated that Volodymyr Tsuman and Veniamin Tsuman have committed 52 thefts across several counties in Washington State with a total loss to their company of over $ 47,260.96.

AGO Investigation

I began my investigation by reviewing thefts alleged to have been committed by Volodymyr and Veniamin Tsuman. This consisted of reviewing the police reports, loss reports and video provided by The Home Depot, as well as interviewing current employees. The investigative information was provided by the company’s Organized Retail Crime Investigator, Ryan W. Lemmers, and detailed the method of theft and connection between both Volodymyr and Veniamin Tsuman. Lemmers’ report documents thefts found through transaction analysis and CCTV review. Lemmers did not witness Volodymyr and Veniamin stealing together, however, most of their observed thefts were tied to transactions on the same credit card, a Visa ending in 0030 belonging to Veniamin Tsuman and tied to a registered Home Depot rewards account in his name. The Anglicized version of his name “Ben” Tsuman appears on the receipt images in this report. Veniamin was often seen physically using this same card ending in 0030 in the stores. Volodymyr most often used a different Visa ending in 4004, also tied to the Veniamin Tsuman rewards account. Through CCTV review of transactions on these two cards, Lemmers was able to find the majority the thefts documented in his report. Please note: the sixteen-digit credit card numbers that appear on the receipt images in the report are an algorithmic substitute for the actual credit card number in which only the last four digits correspond to the actual card number. This is done for information security purposes. Lemmers can request the actual credit card numbers from corporate if needed.

Volodymyr and Veniamin primarily stole merchandise through a method commonly referred to as “double dipping,” in which a receipt from a legitimate purchase is used to walk out of the store with a cartload of similar merchandise. In Volodymyr and Veniamin Tsuman’s case, this was done by placing legitimate Carry-Out orders at either the Professional Services counter or Customer Service counter, prompting the cardholder, Veniamin Tsuman, to confirm the purchase. Once the order was paid for, the subject would receive Pickup Confirmation paperwork listing the items purchased and exit the store with the purchased merchandise. The subject would then re-enter the store, select identical or similar items, and exit with the unpaid/stolen merchandise, showing the paperwork to the cashier if questioned. Due to the large size of Home Depot stores and multiple exits, this type of theft is very difficult for employees in the stores to catch, as the subjects typically exit through a different door with the stolen merchandise than they exited with the legitimately purchased merchandise. Lemmers also observed several thefts in which Volodymyr used the Pickup Confirmation paperwork from one store to steal the same merchandise again from a different store. Lemmers also observed both Volodymyr and Veniamin Tsuman commit thefts through “skip scanning,” which is someone one fails to scan and pay for merchandise at the self-checkout registers. Volodymyr Tsuman was often accompanied by different unidentified white male accomplices who were seen assisting and handling the stolen merchandise, repositioning the vehicle used to transport the stolen merchandise, and loading the stolen merchandise into Tsuman’s van. However, all the interaction with cashiers, transactions at registers and the majority of physically exiting the stores with stolen merchandise was done by Volodymyr. In all but one of Veniamin’s thefts, he was seen working alone.

Identification of Suspects

Lemmers positively identified Volodymyr Tsuman and Veniamin Tsuman through the capture of their driver’s license information in returns they conducted on April 23, 2024, and February 14, 2024, respectively. According to Home Depot records, Volodymyr Tsuman presented WA driver’s license number WDL259TF233B, and Veniamin Tsuman presented WA driver’s license number WDL11N34F5SB. Those refund transactions are detailed on the following pages of this report. Lemmers also found a business website, https://www.vladhardwoodflooring.com/ with pictures of both Volodymyr and Veniamin Tsuman with contact information and a description of their business.

Below is the Home Depot ProXtra rewards account information for both Volodymyr and Veniamin Tsuman. Lemmers only found one theft in which Volodymyr used a card tied to his own ProXtra account. The remaining thefts were all done using the card ending in 0030 and 4004 tied to Veniamin’s ProXtra account. The ProXtra account for Volodymyr Tsuman lists the following personal information. His phone number shows 425-722-9058, email address of Volodymyr.Tsuman@gmail.com, and a billing address of 3732 156th St SW Apt L, Lynwood WA, 98087. The information for Veniamin Tsuman listed was 425-361-9705 with an email address of ben@noemail123.com. His address was listed as 12625 Admiralty Way, Everett WA, 98204.

Lemmers positively identified Volodymr Tsuman through a transaction he conducted at the Everett Home Depot on April 23, 2024. Volodymyr Tsuman conducted a partially non-receipted refund where he presented his driver’s license to process the refund. His license was scanned by the cashier, and his name and an encrypted driver’s license number were captured in the transaction. His decrypted Washington driver’s license number was WDL259TF233B. The credit card receiving a partial refund was the Visa ending in 4004 used by Volodymyr Tsuman in several subsequent in-person transactions. Prior to this refund, Volodymyr committed a felony theft during this same visit (documented later in this report). Volodymyr was also identified at the time of his arrest by Lynnwood Police Department on July 16, 2024.

Lemmers positively identified Veniamin Tsuman when he conducted a partially non-receipted refund at the Everett Home Depot. Veniamin presented his driver’s license to process the refund which the cashier scanned. Veniamin Tsuman’s name and an encrypted driver’s license number was captured in the transaction details. The decrypted driver’s license number is WDL11N34F5SB. One of the cards receiving a partial refund was the Visa ending in 0030 used by Veniamin Tsuman in several subsequent in-person transactions and in carry-out orders placed by Volodymyr Tsuman. A list of transactions associated with Volodymyr and Veniamin Tsuman related to the Home Depot thefts is contained within Lemmers’ report.

Leonid Trotskovets was identified by Lynnwood Police Department officers, when he was contacted with Volodymyr Tsuman in connection with these thefts on July 16, 2024.

Summaries of thefts

Theft 1 - On April 3, 2024, at approximately 9:20 a.m., Volodymyr Tsuman entered the Home Depot store located at 11915 Hwy 99, Everett, Snohomish County, Washington, with an unidentified white male in a tan Mercedes Sprinter van. The license plate on the van was WA C59325W. The registered owner of the van is Vladhardwood Flooring LLC. Tsuman and the unidentified male entered the store through the tool rental door with no merchandise. Tsuman loaded and staged a cart with 23 cases Lifeproof flooring in the electrical section of the store. Tsuman proceeded to the Pro Services counter with a separate cart containing 23 cases of Lifeproof flooring and put the merchandise on a carry out order tied to the Veniamin Tsuman Pro Account. $1643.59 was charged to the Visa ending in 0030 in Ben Tsuman’s name. Volodymyr Tsuman was given a receipt for the transaction and he and the unidentified male left the store and began loading the merchandise in the Sprinter van. Tsuman re-entered the store with no merchandise and retrieved the pre-staged cart of 23 cases of Lifeproof flooring in the electrical section. Volodymyr Tsuman exited the store at the main entrance with this cart of flooring without paying for the merchandise. When the unidentified male was done loading the flooring, he drove the van to the front of the store, meeting up with Tsuman where they loaded the stolen merchandise and left the property. To note, the merchandise is stacked differently in both pictures when Tsuman is exiting the store with both carts. Total loss to Home Depot was $1643.59.

Theft 2 - On April 3, 2024, at approximately 10:18 a.m., less than 20 minutes after leaving the Everett Home Depot, Volodymyr Tsuman and the same unidentified male would arrive at the Home Depot located at 2901 184th St SW, Lynwood, Snohomish County, Washington. Volodymyr Tsuman and the male enter the store with no merchandise. The male staged a cartload of Rapid Set Concrete Leveler in the cleaning products aisle and exited the store through the main exit with no merchandise. Volodymyr Tsuman approached the Pro Services desk with 18 sacks of Rapid Set Concrete Leveler. He put the merchandise on a carry out order tied to the Veniamin Tsuman Pro Account. $638.25 was charged to the Visa ending in 0030 in Ben Tsuman’s name. The cashier gave Volodymyr Tsuman the receipt and he exited the store with the merchandise that was paid for. He handed the cart off to the male who was outside and who proceeded to load the concrete leveler into the Sprinter van. Volodymyr re-entered the store with the receipt through the main exit and retrieved the staged cart of concrete leveler. Volodymyr Tsuman exited the store through the main entrance with the staged cart of concrete leveler without paying for it. When the male was done loading the first cart of concrete leveler, he drove to meet Tsuman in the parking lot. To note, the concrete leveler is stacked differently on both carts when Tsuman is exiting the store. Total loss to Home Depot was $638.25.

Theft 3 - On April 3, 2024, at approximately 8:40 p.m., Volodymyr Tsuman and the same unidentified male returned to the Home Depot store located at 2901 184th St SW, Lynwood, Snohomish County, Washington. The two entered the store through the main entrance without any merchandise. Volodymyr and the male loaded 23 cases of Lifeproof flooring onto a flat cart. Volodymyr also added a pack of paper towels and two five-gallon buckets to the cart. Volodymyr Tsuman and the male proceeded to the self-check-out registers with the merchandise. Tsuman scanned and paid for the paper towels and buckets, with a total purchase of $43.07. A cashier in the section approached and motioned to the flooring on the cart. Tsuman motioned toward a piece of paper on top of the flooring. The cashier inspected the paper and allowed Tsuman and the male to exit without paying for the merchandise. The flooring matched what was purchased earlier in the day at the Home Depot in Everett. Total loss to Home Depot was $1643.59.

Theft 4 – On April 3, 2024, at approximately 9:09 p.m., less than 15 minutes after leaving the Lynnwood Home Depot, Volodymyr Tsuman and the same male arrive at the Home Depot store located at 11915 Hwy 99, Everett, Snohomish County, Washington. Volodymyr Tsuman and the male enter the store through the main entrance with no merchandise. They proceed to the building materials section and load a cart of Rapid Set Concrete Leveler, which they leave staged in the store. Tsuman and the male proceed to load a cart with 23 cases of Lifeproof flooring. Tsuman and the male approach a register and show a cashier paperwork. Tsuman pays for three five-gallon buckets for a total of $14.85, using the Visa ending in 4004. The flooring on the cart was not paid for, prior to the two exiting the store. Tsuman and the male exit the store with the stolen merchandise. The store loss for the flooring is $1643.59. Volodymyr Tsuman re-enters the store without any merchandise and paperwork in his hand. He retrieves the pre-staged cart of concrete leveler and exits the store through the main entrance without paying. The store loss for the concrete leveler is $638.25, with a total combined loss for the store of $2281.84. The unidentified male would drive to another part of the parking lot to meet Tsuman and load the concrete leveler into the van before leaving.

Theft 5 - On April 8, 2024, at approximately 7:15 p.m., Volodymyr Tsuman and the same male from April 3rd, arrive in the tan Sprinter van at the Home Depot Store located at 2901 184th St. SW, Lynwood, Snohomish County, Washington. The two enter the store with no merchandise in hand. They proceed to the building materials section. Tsuman would emerge from an aisle pulling a cart loaded with 17 sacks of Rapid Set Concrete Leveler. The male was not with him at this time. Tsuman would contact the Customer Service registers where he paid for the concrete leveler, two rolls of masking tape and a bottle of concrete bonding adhesive on a carry out order tied to the Veniamin Tsuman Pro Account using the credit card ending in 0030. $621.78 was the total purchase price. The male joined back up with Tsuman while he was in line. After walking out the door with the merchandise, Volodymyr Tsuman immediately re-enters the store holding the carry-out paperwork. A few minutes later, Tsuman is seen on CCTV with a second cart load of 17 sacks of Rapid Set Concrete Leveler, a bottle of concrete adhesive and a pack of masking tape. Tsuman approached the cashier and showed them the carry-out paperwork. Tsuman paid for a case of bottled water and a box of diesel exhaust fluid, which totaled $23.51, using the Visa card ending in 0030. Tsuman did not pay for the concrete leveler, adhesive or masking tape. He exited the store from a different exit than the male. Tsuman proceeded to the Sprinter van where he and the male loaded the merchandise into the tan Sprinter van. Total loss to Home Depot was $621.78.

Theft 6 - On April 12, 2024, at approximately 1:23 p.m., Volodymyr Tsuman purchased 16 sacks of Rapid Set Concrete Leveler and a bottle of concrete bonding adhesive on a carry out order tied to the Veniamin Tsuman Pro account. The transaction was conducted at the Home Depot store located at 1101 Kingswood Dr SW, Tumwater, Thurston County, Washington. $573.52 was charged to the Visa card ending in 0030 in Ben Tsuman’s name. The cashier provided Volodymyr Tsuman with a receipt for the transaction. Tsuman and the same unidentified male exited the store, with Tsuman turning around and re-entering the store with no merchandise. Tsuman would appear with a cart loaded with 16 sacks of concrete leveler and a bottle of concrete bonding adhesive. Tsuman proceeded to the self-checkout register and purchased two Red Bull energy drinks. Tsuman paid $8.07 using the Visa ending in 4004, not scanning or paying for the concrete leveler or adhesive. Tsuman was not contacted by the cashier during the transaction. Tsuman exited the store with the stolen concrete leveler and adhesive. Total loss to the store was $573.52.

Theft 7 - On April 12, 2024, at approximately 6:15 p.m., Volodymyr Tsuman and the same unidentified male arrived at the Home Depot store located at 325 120th Ave NE, Bellevue, King County, Washington in the tan Sprinter van. This is approximately 5 hours after being at the store in Tumwater. They entered the store without any merchandise. Volodymyr Tsuman was holding some paperwork in his hand. The two are seen on camera pushing a cart loaded with 16 sacks of Custom Building Products LevelQuik self-leveling underlayment and a gallon of RedGuard waterproofing membrane. They proceeded to a self-check-out register. Tsuman scanned two 4.5 inch cutting discs and a three pack of hi-vis work gloves, but did not scan any of the other items. He paid for the three items, which totaled $19.19, using the credit card ending in 0030. The cashier approached and inspected the paperwork Tsuman motioned to on the top of the other merchandise. The underlayment and waterproofing membrane were not scanned and paid for. Tsuman and the unidentified male exited the store with the stolen merchandise and loaded it into the Sprinter van. The total loss to the store was $519.65.

Theft 8 - On April 12, 2024, at approximately 7:06 p.m., Volodymyr Tsuman and the same unidentified male arrived at the Home Depot located at 2901 184th St. SW, Lynnwood, Snohomish County, Washington, in the tan Sprinter van. This is less than 30 minutes after leaving the Bellevue store. The two entered the store through the main entrance with no merchandise in hand. Tsuman was carrying paperwork with him. They proceeded to the flooring area and appeared with a cart loaded with 16 sacks of LevelQuik self-leveling underlayment and a gallon of RedGuard waterproofing membrane. They proceeded to a self-check-out register. Tsuman scanned and paid for a pack of paper towels, but not the other items on the cart. They were not contacted by the cashier and left the store, not paying for the underlayment and waterproofing membrane. Total loss to the store was $519.65.

Theft 9 - On April 17, 2024, at approximately 6:51 p.m., Volodymyr Tsuman and the same unidentified male arrived at the Home Depot store located at 2901 184th St. SW, Lynnwood, Snohomish County, Washington. They were in the tan Sprinter van driven by Tsuman. Tsuman approached the Customer Service counter with 18 sacks of Rapid Set Concrete Leveler, a quart of Sika Concrete Bonding Adhesive and a pair of gloves. Tsuman put the merchandise on a carry-out order tied to the Veniamin Tsuman Pro Account. $655.03 was charged to the Visa ending in 0030 in Ben Tsuman’s name. Volodymyr Tsuman was provided paperwork for the transaction. He and the male left the store with the purchased merchandise. Tsuman immediately re-entered the store with the carryout paperwork. The male loaded the purchased merchandise into the van. Tsuman would emerge from the lumber aisle with another eighteen sacks of Rapid Set Concrete Leveler, a quart of Sika Concrete Bonding Adhesive and pack of gloves. He approached register 1 and selected a case of bottled water. The cashier motioned at the items on the cart and Tsuman held up the paperwork. Tsuman only paid for the case of bottled water, paying $5.51 using the Visa ending in 4004. Tsuman exited the store with the stolen merchandise. He and the male loaded the merchandise into the van and left. Total loss to the store was $655.03.

Theft 10 - On April 17, 2024, at approximately 7:30 p.m., Volodymyr Tsuman and the unidentified male arrived at the Home Depot store located at 11915 Highway 99, Everett, Snohomish County, Washington. This was approximately 16 minutes after leaving the Lynwood store. They parked the Sprinter van near the lumber entrance. Tsuman and the male entered the store via the lumber entrance with no merchandise in hand and made their way to the building materials. Tsuman had paperwork in his hand. The two approached a checkout register with a cart containing 18 sacks of Rapid Set Concrete Leveler. Tsuman gave the cashier the paperwork, and only paid for a broom, not the sacks of concrete leveler. The items on the cart matched the items from the Lynnwood transaction less than 30 minutes prior. The broom cost $10.46 and he used the Visa card ending in 4004. Tsuman and the male left the store with the stolen concrete leveler without paying for it. Total loss to the store is $655.03.

Theft 11 - On April 19, 2024, at approximately 7:18 a.m., Volodymyr Tsuman arrived at the Home Depot store located at 9310 Quil Ceda Blvd., Marysville, Snohomish County, Washington, driving the tan Sprinter van. Tsuman entered the store via the lumber exit with no merchandise, but some paperwork in his hand. He proceeded to the building materials aisle. He emerged from the building materials area with a cart loaded with 18 sacks of LevelQuik Self Leveling Underlayment. He put three five-gallon buckets on the cart as well. Tsuman went to the self-check-out register with the cart. Paperwork was on top of the underlayment sacks. Tsuman scanned and paid for only three buckets, paying $22.85 using a debit card in the name “Volodymyr” ending in 9582. The phone number on the receipt ties to a Home Depot ProXtra account belonging to Volodymyr Tsuman. The cashier did not scrutinize the paperwork on the sacks. Tsuman left the store without paying for the underlayment sacks, loaded them in the Sprinter van and left. Total loss to the store was $521.64.

Legitimate Purchase - On April 19, 2024, at approximately 8:53 a.m., Volodymyr Tsuman made a legitimate purchase from the Everett Home Depot located at 11915 Highway 99, Everett, Snohomish County, Washington. Tsuman purchased 21 sacks of LevelQuik Self Leveling Underlayment, two tubes of caulk, a quart of LevelQuik primer and three rolls of masking tape on a carry-out order tied to the Veniamin Tsuman Pro Account. $748.86 was charged to the Visa ending in 0030 in Ben Tsuman’s name. The cashier provided Volodymyr Tsuman with receipt paperwork for the purchase when complete. Tsuman was with an unidentified white male who hadn’t been seen previously. The white male was approximately 50 years old. The two loaded the merchandise into the Sprinter van and left the property.

Theft 12 - On April 19, 2024, at approximately 5:17 p.m., Volodymyr Tsuman and the younger unidentified male seen in previous transactions arrived in the Sprinter van at the Home Depot store located at 6200 E Lake Sammamish Pkwy, Issaquah, King County, Washington. Tsuman and the male entered the store through the lumber exit with no merchandise and went to the building materials section. Tsuman had some paperwork in hand. Tsuman and the male emerged from the lumber aisle with a cart loaded with 21 sacks of LevelQuik Self Leveling Underlayment, three rolls of masking tape and a gallon of Red Guard waterproofing membrane. Tsuman approached a register with the cartload of merchandise and showed paperwork to the cashier. Except for a few different items, this merchandise matched the items from the legitimate purchase at 8:53 a.m. at the Everett Home Depot. The cashier did not appear to closely examine the paperwork. Tsuman purchased three buckets and three bottles of Sprite, paying $23.03 using the Visa ending in 4004. Tsuman did not pay for any of the other merchandise on the cart. Total loss for the store was $697.94.

Legitimate Purchase - On April 23, 2024, at approximately 9:06 a.m., Volodymyr Tsuman and two unidentified males, both of which had previously been seen with him, made a legitimate purchase at the Home Depot store located at 11915 Highway 99, Everett, Snohomish County, Washington. Tsuman put fifty 16 ft. 2x6s, a 25 lb. box of screws and a 10 lb. box of screws on a carry-out order tied to the Veniamin Tsuman Pro Account. $855.76 was charged to the Visa ending in 0030 in Ben Tsuman’s name. The cashier handed Volodymyr Tsuman paperwork at the completion of the transaction. The merchandise was loaded into the Sprinter van, and they left the property.

Theft 13 - On April 23, 2024, at approximately 7:51 p.m., Volodymyr Tsuman and the same younger unidentified male seen previously arrived at the Home Depot store located at 11915 Highway 99, Everett, Snohomish County, Washington. The male entered the store a few minutes prior to Tsuman. Approximately 17 minutes later, Tsuman and the male approached a register with a cart loaded with 50 16 ft. 2x6s and two boxes of screws, identical to those on the 9:06 a.m. order. Tsuman showed the paperwork to the cashier and only paid for three cans of Great Stuff foam and a pack of shims, paying $16.49 using the Visa ending in 4004 in Ben Tsuman’s name. The two left the store with the stolen merchandise, which totaled $855.76. Approximately seven minutes later, Volodymyr Tsuman re-entered the store via the main entrance with no merchandise yet carrying some paperwork. Tsuman would appear with a cart loaded with 18 sacks of Rapid Set Concrete Leveler and a gallon of Sika Concrete Bonding Adhesive. Tsuman exited the store via the main entrance, bypassing all points of sale without paying for any of the merchandise on the cart. The loss for to the store was $627.42. The total loss to the store combined was $1483.18.

Theft 14 - On April 24, 2024, at approximately 6:08 p.m., Volodymyr Tsuman and the unidentified male previously seen arrived at the Home Depot store located at 2901 184th St. SW, Lynnwood, Snohomish County, Washington. They went to a lumber aisle and loaded up a cart with fifty 16 ft. 2x6’s, and two boxes of screws, which was the same purchase they made the previous day in the Everett store. Tsuman presented paperwork to the cashier at a register and proceeded to only pay for a box of diesel exhaust fluid and three buckets. He used the Visa card ending in 4004. The two exited the store and loaded the stolen merchandise into the Sprinter van before leaving. Total loss to the store was $855.76.

Theft 15 - On April 29, 2024, at approximately 1:54 p.m., Volodymyr Tsuman and the older unidentified male previously seen were at the Home Depot store located at 2908 184th St SW, Lynwood, Snohomish County, Washington. They approached the customer service register with 18 sacks of Rapid Set Concrete Leveler. Tsuman put the merchandise on a carry out order tied to the Veniamin Tsuman Pro Account. $638.25 was charged to the Visa card ending in 0030 in Ben Tsuman’s name. Volodymyr Tsuman was provided with paperwork for the transaction. He and the older unidentified male exited the store with the merchandise. After leaving the store, Tsuman re-entered with no merchandise, but the paperwork was still in his hand. Minutes later, Tsuman appeared exiting the lumber aisle with a second cart loaded with 18 sacks of Rapid Set Concrete Leveler and 3 buckets. Tsuman approached the cashier at the lumber exit, different than the customer service counter, and showed them the paperwork. Tsuman paid for the three buckets using the Visa card ending in 4004. Now accompanied by the younger unidentified male, they left the store without paying for the concrete leveler. Total loss to the store was $638.25.

Theft 16 - On April 29, 2024, at approximately 8:13 p.m., Volodymyr Tsuman entered the Home Depot store located at 9301 Quil Ceda Blvd., Marysville, Snohomish County, Washington. He was not carrying any merchandise. Approximately eight minutes later Tsuman would proceed to the self-check-out register with a cart loaded with 18 sacks of Rapid Set Concrete Leveler, buckets and other smaller items. Tsuman would scan the buckets and smaller items but did not scan and pay for the concrete leveler. He paid for the buckets and smaller items using the Visa card ending in 4004 and exited the store. Tsuman loaded the buckets and smaller items, along with the stolen concrete leveler into the Sprinter van prior to leaving. Total loss to the store was $638.25.

Theft 17 - On April 30, 2024, at approximately 2:52 p.m., Volodymyr Tsuman and the older unidentified male previously seen approached the customer service counter at the Home Depot store located at 11915 Highway 99, Everett, Snohomish County, Washington. Tsuman had previously entered the store with the younger unidentified male seen in previous thefts. He and the older male had a cart loaded with 22 sacks of Rapid Set Concrete Leveler. Tsuman paid for the concrete leveler by placing it on a carry out order tied to the Veniamin Tsuman Pro Account and utilized the Visa card ending in 0030 in Ben Tsuman’s name. The total price was $779.38, and Volodymyr Tsuman was presented with paperwork for the transaction. Tsuman and the older male then approached the self-check-out register and purchased a case of water using the Visa card ending in 4004. When done, the older male left the store with the concrete leveler and water, loading them into the Sprinter van in the loading zone near the lumber exit. Tsuman did not exit the store, returning to the shopping area. Volodymyr Tsuman appeared back in the store approximately two minutes later with a cart loaded with 22 sacks of concrete leveler. Tsuman exited the store with the cart of concrete leveler through the main entrance, passing all points of sale without paying for the merchandise. Tsuman waited outside of the store in the parking lot. A few minutes after exiting the store with the stolen merchandise, the younger male exited and contacted Tsuman briefly. During this time, the older male loaded the purchased merchandise into the Sprinter van. The younger male would walk to the van after leaving Tsuman, get in the driver’s seat and drive the van to where Tsuman was in the parking lot. The three loaded the stolen concrete leveler into the van. They departed the property when done. Total loss to the store was $779.38.

Theft 18 - On April 30, 2024, at approximately 7:54 p.m., Volodymyr Tsuman came back to the Home Depot store located at 11915 Highway 99, Everett, Snohomish County, Washington. This was approximately 5 hours after the first theft. Tsuman entered through the lumber exit with no merchandise. He would appear in the store on CCTV with a cart of 22 sacks of Rapid Set Concrete Leveler, the same number as earlier in the day. He would proceed to the self-checkout register and scan and pay for a Coke, three rat traps, a pack of rodent repellant and a bucket, paying $50.54 using the Visa ending in 4004. Tsuman did not pay for any of the concrete leveler. The total loss to the store was $779.38. He would exit the store near the lumber loading zone with the stolen merchandise. At this point he could not be seen via surveillance camera. The time was 8:06 p.m.

At 8:11 p.m. the tan Sprinter van, with WA license plate C59325W, driven by Tsuman passed the tool rental center. He would exit the parking lot, only to re-enter the parking lot in a different area, parking near the main entrance. At 8:15 p.m., Tsuman re-enters the store with no merchandise. Twelve minutes later he is at the Customer Service register with 22 sacks of LevelQuik Self Leveling Underlayment and a bucket. Tsuman put the merchandise on a carry-out order tied to the Veniamin Tsuman Pro Account. $638.96 was charged to the Visa ending in 0030 in Ben Tsuman's name. The cashier provided Volodymyr Tsuman paperwork at the completion of the transaction. Tsuman would exit the store and load the merchandise into the Sprinter van before leaving.

Theft 19 - On May 2, 2024, at approximately 10:25 a.m., Volodymyr Tsuman was at the Home Depot store located at 4602 Center St., Tacoma, Pierce County, Washington. Two unidentified males were with him. The older male previously seen, and a younger male who had not. At the Professional Services register, Tsuman purchased eighteen sacks of Rapid Set Concrete Leveler. The younger male was with Tsuman. Volodymyr Tsuman put the merchandise on a carry-out order tied to the Veniamin Tsuman Pro Account. $636.52 was charged to the Visa ending in 0030 in Ben Tsuman's name. Near the end of the transaction, the older male approached and contacted VolodymyrTsuman. The cashier provided Tsuman paperwork at the completion of the transaction. When the transaction was complete, the two unidentified males exited the store with the purchased merchandise. Tsuman went to the building materials section and approximately three minutes later approached a manned register with a cart loaded with another 18 sacks of concrete leveler. Tsuman provided the cashier with the paperwork from the legitimate transaction from minutes before and purchased a bucket and three Coke’s. He used the Visa card ending in 4004 for the small transaction. Tsuman exited the store without paying for the 18 sacks of concrete leveler. Total loss to the store was $636.52.

Theft 20 - On May 2, 2024, at approximately 12:13 p.m., Veniamin Tsuman was at the Home Depot store located at 901 S. Grady Way, Renton, King County, Washington. He approached the Professional Services register with 18 pieces of base trim, two electrical wall plates, two electrical boxes, six 8-packs of base trim, two pairs of gloves and a Schlage lock set. Tsuman placed the items on a carry-out order in his company name, paying $842.27 using the Visa ending in 0030. At the conclusion of the transaction, the cashier handed Veniamin Tsuman paperwork. Tsuman exited the store and loaded the merchandise into a white Mercedes Sprinter van. After loading the merchandise into the van, Tsuman re-entered the store through the main entrance with no merchandise yet carrying paperwork with him. Tsuman would appear from the cleaning products aisle with a second cart of similar merchandise and exit the store through the main entrance, bypassing all points of sale without paying. Tsuman loaded the merchandise into the Sprinter van and left the property. Total loss to the store was $842.27.

Theft 21 - On May 3, 2024, at approximately 8:24 a.m., Volodymyr Tsuman was at the Home Depot store located at 11915 Highway 99, Everett, Snohomish County, Washington. He made a legitimate purchase of a box of backer board screws, two sacks of LevelQuik Self Leveling Underlayment, a gallon of RedGuard water proofing membrane, a quart of LevelQuik primer, two sacks of Sakrete sand mix, a Ridgid tile saw blade, two rolls of masking tape, three aluminum tile trims, a 100 ft. roll of X-Board, two tubes of caulk, eight 3x5 ft. Hardi backerboards, a roll of blue painters tape, a roll of cement mesh tape, five sacks of Prolite tile mortar, a trowel and two 100-packs of tile spacers on a carry-out order tied to the Veniamin Tsuman Pro Account. $886.13 was charged to the Visa ending in 0030 in Ben Tsuman's name. The cashier handed Volodymyr Tsuman paperwork at the completion of the transaction. Tsuman and the younger unidentified male previously seen exited the store with the purchased merchandise.

On the same day at 8:49 p.m., Volodymyr Tsuman and the same younger male in previous thefts arrived at the Home Depot store located at 2901 184th St. SW, Lynnwood, Snohomish County, Washington, in the tan Sprinter. Tsuman and the male entered the store at different times with no merchandise in hand. They proceeded to the building materials section. Approximately 10 minutes later they emerged with a cart loaded with similar items purchased at the Everett store earlier in the day. Tsuman showed the carry-out paperwork to the cashier and paid for a box of trash bags and a box of diesel exhaust fluid, paying $40.09 using the Visa ending in 4004. Tsuman and the male exited with the stolen merchandise, loaded it in into the tan Sprinter Van and departed. Total loss to the store was $886.13.

Theft 22 - On May 7, 2024, at approximately 12:34 p.m., Volodymyr Tsuman and the younger unidentified male were at the Home Depot Store located at 11915 Hwy 99, Everett, Snohomish County, Washington. Tsuman put thirty cases of Lifeproof flooring, twelve sacks of Rapid Set Concrete Leveler, a roll of Gorilla tape and a case of bottled water on a carry-out order tied to the Veniamin Tsuman Pro Account. $2439.48 was charged to the Visa ending in 0030 in Ben Tsuman's name. The cashier handed Volodymyr Tsuman paperwork at the completion of the transaction. Tsuman and the male exited the store with the merchandise.

On the same day, at approximately 7:48 p.m., Volodymyr Tsuman and same male returned to the Everett Home Depot store in the tan Sprinter van driven by Tsuman. They entered the store with no merchandise and separated while in the store. Approximately 16 minutes later they would appear on CCTV leaving the building materials section with similar items that were purchased earlier in the day. Tsuman scanned a box of trash bags and three cases of bottled water, paying $49.63 using the Visa ending in 4004. Tsuman did not scan or pay for any of the flooring or concrete leveler on either cart. They would exit the store with the stolen merchandise, load it into the tan Sprinter van and leave the property. Total loss to the store was $2439.48.

Theft 23 - On May 9, 2024, at approximately 12:53 p.m., Volodymyr Tsuman and a younger unidentified male previously seen, entered the Home Depot store located at 2901 184th St. SW, Lynwood, Snohomish County, Washington. The two entered the store with a shopping cart loaded with different tiling materials. Tsuman proceeded to the returns desk while the male moved to the interior of the store. Tsuman would receive a credit for the returned items in the amount of $312.69 onto the Visa card ending in 4004. Those items matched merchandise that was both purchased and stolen from the Everett Home Depot on May 3, 2024. While Tsuman was at the returns desk, the male would appear on CCTV pushing a cart loaded with 20 sacks of LevelQuik Self Leveling underlayment. The male left the cart at the front of an aisle and joined Tsuman. When completed at the returns desk, Tsuman and the male proceeded to leave the store with the staged cart of underlayment, passing all points of sale without paying for it. They loaded the stolen merchandise into the tan Sprinter van and left the property. Total loss to the store was $579.60.

Theft 24 - On May 10, 2024, at approximately 9:22 a.m., Volodymyr Tsuman made a legitimate purchase at the Home Depot store located at 11915 Hwy 99, Everett, Snohomish County, Washington. Tsuman purchased seventeen 16 ft 2x6s, 22 sheets of oriented strand board, five energy drinks, a box of staples, a DeWalt taping knife, a bucket and ten pieces of metal flashing on a carry-out order tied to the Veniamin Tsuman Pro Account. $901.23 was charged to the Visa ending in 0030 in Ben Tsuman's name. The cashier was unable to print paperwork at the completion of the transaction. Volodymyr Tsuman took a picture of the screen. Tsuman exited the store with three unidentified males and put the purchased merchandise into a white Sprinter van which bore WA license CJK6762.

Later that same day at approximately 7:37 p.m., Volodymyr Tsuman and the younger unidentified male seen previously returned to the Everett Home Depot. They entered via the main entrance/exit and didn’t have any merchandise in hand. Tsuman and the male proceeded to the customer service register where Tsuman received a printout of the previous carry out order. He did not buy or return anything. They would then go to the lumber section and emerge with similar items to those purchased earlier that day. They approached a register and showed the cashier paperwork. Tsuman paid for two packs of gloves and a razor scraper, paying $39.13 using a store credit gift card. Tsuman did not scan or pay for any lumber or plywood on the cart. They exited the store with the merchandise they didn’t pay for and loaded it into the tan Sprinter van before leaving. Total loss to the store was $901.23.

Theft 25 - On May 13, 2024, at approximately 12:39 p.m., Veniamin Tsuman arrived at the Home Depot store located at 17777 NE 76th St., Redmond, King County, Washington. Tsuman did not have any merchandise with him and utilized a shopping cart while selecting items. Tsuman selected a Ridgid wet/dry blower vacuum, a Ridgid vacuum accessory kit and a 2-pack of Ridgid vacuum filters. He also selected a box of Husky garbage bags, two Diablo edger discs and a case of bottled water. Tsuman scanned and paid for the garbage bags, edger discs and water. He paid $48.72 using the Visa ending in 0300. He did not scan and pay for any of the Ridgid vacuum items in the cart. Tsuman left the store with the items in the cart, to include the vacuum and accessories he didn’t pay for. Total loss to the store was $218.94.

Theft 26 - On May 17, 2024, at approximately 1:35 p.m., Volodymyr Tsuman and the same unidentified male seen in previous thefts contacted the Home Depot store located at 2901 184th St. SW, Lynwood, Snohomish County, Washington. Tsuman purchased 21 sacks of Rapid Set Concrete Leveler, two tubes of caulk, a bucket and two packs of masking tape on a carry-out order tied to the Veniamin Tsuman Pro Account. $768.63 was charged to the Visa ending in 0030 in Ben Tsuman's name. At the conclusion of the transaction, the cashier handed Volodymyr Tsuman paperwork. Tsuman exited the store with the purchased merchandise and contacted the male in the parking lot. The male loaded the merchandise into the tan Sprinter van. Tsuman returned to the interior of the store carrying the paperwork. Approximately three minutes later, Tsuman would appear on CCTV from the electrical aisle with a second cart of similar merchandise to what he just purchased. He exited with the second cart via the main exit, passing all points of sale, without paying for the merchandise. When the male was finished loading the first cart of merchandise, he drove to and met up with Tsuman in another area of the parking lot. The two of them loaded up the stolen merchandise and left the property. Total loss to the store was $768.63.

Theft 27 - On May 17, 2024, at approximately 7:02 p.m., Veniamin Tsuman was at the Home Depot Store located at 11915 Hwy 99, Everett, Snohomish County, Washington. Veniamin Tsuman purchased twenty-five sacks of LevelQuik Self Leveling Underlayment on a carry-out order tied to his Pro Account. $901 .23 was charged to the Visa ending in 0030 in his name. The cashier handed Tsuman paperwork at the conclusion of the transaction. Tsuman exited the store and placed the merchandise into a white Sprinter van. Two hours later, at 9:02 p.m., Veninamin Tsuman re-entered the store pulling a cart with no merchandise on it. He was carrying paperwork. Ten minutes later he appeared from the appliance aisle with 31 sacks of LevelQuik Self-Leveling Underlayment. He walked out of the store via the main entrance/exit, passing all points of sale without paying for the merchandise. A cashier had a short conversation with him while he was exiting but did not check the paperwork on the cart. Total loss to the store was $898.38.

Theft 28 - That same day, May 17, 2024, at approximately 9:01 p.m., Volodymyr Tsuman and the younger unidentified male previously seen returned to the Home Depot store located at 2901 184th St. SW, Lynnwood, Snohomish County, Washington. They entered the store through the lumber entrance with no merchandise. Approximately nine minutes later they emerged with 21 sacks of Rapid Set Concrete Leveler, two cases of Alex Caulk, a bucket and two packs of masking tape, similar to the items on the 1:35 p.m. order. Volodymyr and the male approached self-checkout register 52 with the cartload of merchandise. Volodymyr showed carry-out paperwork to the cashier. Volodymyr paid for two Avanti Pro masonry cutting discs and a box of trash bags, paying $27.55 using the Visa ending in 4004. Volodymyr did not scan or pay for any of the Concrete Leveler, caulk, bucket or masking tape. They exited the store with the stolen merchandise. Total loss to the store was $768.63.

Theft 29 - On May 29, 2024, at approximately 4:23 p.m., Volodymyr Tsuman entered the Home Depot store located at 1335 N 205th St., Shoreline, King County, Washington. He purchased 18 cases of Lifeproof flooring on a carry-out order tied to the Veniamin Tsuman Pro Account. $1245.78 was charged to the Visa ending in 0030 in Ben Tsuman's name. At the conclusion of the transaction, the cashier handed Volodymyr Tsuman paperwork. Tsuman and an unidentified male not previously seen exited the store with the merchandise. The male continued to the tan Sprinter van with the merchandise and began loading it. Tsuman went back into the store with no merchandise carrying the paperwork from the previous transaction. Tsuman proceeded into an electrical aisle and within two minutes appeared again with another cart load of 18 packs of Lifeproof flooring. Tsuman proceeded to the self-checkout register and purchased a small can of paint for $13.17. He used the Visa ending in 4004. He did not scan and pay for the 18 packs of Lifeproof flooring. Tsuman exited the store with the stolen merchandise and loaded it into the tan Sprinter van before leaving. Total loss to the store was $1245.78.

Theft 30 - On May 29, 2024, at approximately 7:08 p.m., less than three hours after the theft in Shoreline, Volodymyr Tsuman entered the Home Depot store located at 2901 184th St SW, Lynwood, Snohomish County, Washington. He was accompanied by an unidentified male not previously seen who entered approximately a minute later. Neither were carrying any merchandise. Tsuman and the male would appear with a cart loaded with 18 packs of Lifeproof flooring. They proceeded to a self-checkout register where Tsuman paid $34.56 for a broom and a box of diesel exhaust fluid with the Visa card ending in 4004. Tsuman did not pay for the flooring. They exited the store and loaded the flooring into the tan Sprinter van. Total loss to the store was $1245.78.

Theft 31 - On June 3, 2024, at approximately 8:01 p.m., Volodymyr Tsuman was at the Home Depot store located at 11915 Hwy 99, Everett, Snohomish County, Washington. At the customer service counter Tsuman purchased a shower pan liner, a box of backer board screws, eleven sacks of Prolite mortar, a quart of Levelquik primer, three gallons of Redgard waterproofing membrane, a roll of X-Board floor protector, a roll of backerboard tape, four 100-packs of tile spacers and three sacks of tile mortar. Volodymyr Tsuman put the merchandise on a carry-out order tied to the Veniamin Tsuman Pro Account. $862.78 was charged to the Visa ending in 0030 in Ben Tsuman's name. The cashier handed Volodymyr Tsuman paperwork at the completion of the transaction. He and an unidentified male exited the store with the merchandise. The unidentified male proceeded to the tan Sprinter van and began loading the merchandise. Tsuman re-entered the store with the carry out paperwork but no merchandise. Within approximately three minutes he retrieved a cart loaded with similar items to those he just purchased. Tsuman proceeded to a register, where he presented the paperwork to the cashier. He would pay for a case of bottled water, a bottle of drain opener and a box of trash bags, paying $52.96 in cash. Tsuman did not pay for the other items loaded on the cart. He exited the store, loaded the stolen merchandise into the Sprinter van and left. Total loss to the store was $862.78.

Theft 32 - On June 3, 2024, at approximately 8:51 p.m., less than 40 minutes from the theft in Everett, Volodymyr Tsuman arrived at the Home Depot store located at 9300 Quil Ceda Blvd., Marysville, Snohomish County, Washington. Tsuman entered the store with no merchandise but appeared to be carrying some paperwork. Tsuman would appear from the plumbing aisle with a cart matching the items from the Everett theft earlier. In addition to those items, Tsuman had varying different plumbing items in a bucket, which he paid for that totaled $201.68. He did not scan or pay for the other items on the cart. In addition to the items on the cart that matched the theft in Everett, was a Moen shower faucet set with spider wrap theft deterrent that totaled $209.00. Tsuman exited the store with the stolen merchandise.

Tsuman loaded the stolen faucet into the van and re-entered the store with the rest of the stolen merchandise on the cart. Tsuman approached the customer service counter and proceeded to return and receive a “refund” for $862.78 onto the card ending in 0030 and a $201.68 refund onto the card ending in 4004 for all the plumbing fittings he just purchased. When done, Tsuman left the store and exited the property. Total loss to the store was $1071.78.

Theft 33 - On June 4, 2024, at approximately 4:17 p.m., Volodymyr Tsuman and an unidentified malearrived at the Home Depot store located at 121 Military Rd. E., Tacoma, Pierce County, Washington. Tsuman and the male off loaded 18 cases of Lifeproof flooring from the tan Sprinter van onto a cart and entered the store. Tsuman received a return amount of $1245.78 which was returned to the card ending in 0030. When the refund transaction was complete, Tsuman and the male proceeded to the lumber section of the store. They would load forty 4x8 ft sheets of siding valued at $39.92 each, two sacks of Rapid Set self-leveling underlayment valued at $33.75 each, two cases of Liquid Nails construction adhesive valued at $72.96 each, a gallon of Sika Level underlayment primer valued at $19.54, and a box of Husky contractor bags valued at $29.97 onto a cart. Volodymyr and the male exited the store via the lumber exit, passing all points of sale without paying for any merchandise on the cart. Volodymyr, the male in the store with him, and a third unidentified male loaded the stolen merchandise into the tan Sprinter van and departed. The total loss to the store was $1859.79.

Theft 34 - On June 5, 2024, at approximately 1:17 p.m., Volodymyr Tsuman arrived at the Home Depot store located at 2901 184th St. SW, Lynnwood, Snohomish County, Washington. Tsuman purchased 15 sacks of Rapid Set Concrete Leveler and a bucket on a carry-out order tied to the Veniamin Tsuman Pro Account. $536.83 was charged to the Visa ending in 0030 in Ben Tsuman's name. While Volodymyr Tsuman was at the counter, an unidentified male who arrived with him, appeared on CCTV pulling a second cart of with 15 sacks of Rapid Set Concrete Leveler. The male staged this cart in the paint aisle and met back up with Tsuman. Tsuman was provided with paperwork for the transaction. He and the male exited the store with the merchandise he paid for. The male proceeded to the tan Sprinter van and loaded the merchandise. Tsuman re-entered the store with paperwork in his hand but no merchandise. Within a minute, he had retrieved the second staged cart of concrete leveler the male had placed in the paint aisle. Tsuman also added a couple of buckets to the cart before walking out of the store, passing all points of sale, without paying for the merchandise. The merchandise was loaded into the tan Sprinter van prior to Tsuman departing the parking lot. Total loss to the store was $536.83.

Theft 35 - On June 10, 2024, at approximately 8:27 a.m., Volodymyr Tsuman and an unidentified male seen in previous thefts arrived at the Home Depot Store located at 2901 184th St. SW, Lynnwood, Snohomish County, Washington. They entered through the lumber exit with no merchandise. Tsuman had some paperwork in hand. They proceeded to the building materials section with a cart. Tsuman and the male appeared with the cart loaded with 15 sacks of Rapid Set Concrete Leveler and at least one bucket and approached the self-checkout register. Tsuman scanned a sack of Sakrete mortar but did not scan the concrete leveler on the cart. He paid $10.91 for the sack of mortar using the Visa card ending in 4004. The male took control of the cart and exited the store. Tsuman then purchased two soft drinks utilizing the Visa card ending in 4004 again. Tsuman and the male loaded the stolen merchandise into the tan Sprinter van and left. Total loss to the store was $506.25.

Theft 36 - On June 10, 2024, at approximately 8:36 p.m., Volodymyr Tsuman and the same unidentified male came back to the Home Depot located at 2901 184th St. SW, Lynnwood, Snohomish County, Washington. Tsuman approached the customer service counter and purchased 16 cases of Home Decorator’s Collection flooring. He put the merchandise on a carry-out order tied to the Veniamin Tsuman Pro Account. $994.87 was charged to the Visa ending in 0030 in Ben Tsuman's name. The cashier handed Volodymyr Tsuman paperwork at the completion of the transaction. Tsuman and the male exited the store, with the male taking the cart of merchandise to the tan Sprinter van. Tsuman re-entered the store with no merchandise but had the carry out paperwork in hand. He proceeded up a hardware aisle and appeared approximately 10 minutes later with a cart loaded with another 16 cases of flooring. Tsuman went to the self-checkout register with the cart. He scanned and paid $31.97 for a tape measure and two containers of floor putty using the Visa card ending in 4004. When a cashier approached, Tsuman showed them the paperwork he had. Tsuman did not scan and pay for the flooring on the cart. Tsuman exited the store with the stolen merchandise, loaded it into the Sprinter van and left. Total loss to the store was $994.87.

Theft 37 - On June 14, 2024, at approximately 3:01 p.m., Volodymyr Tsuman made a legitimate flooring purchase at the South Seattle Home Depot, located at 2701 Utah Ave. South, Seattle, King County, Washington. Tsuman put 25 cases of Home Decorator's Collection flooring on a carry-out order tied to the Veniamin Tsuman Pro Account. $1550.97 was charged to the Visa ending in 0030 in Ben Tsuman's name. The cashier handed Volodymyr Tsuman paperwork at the conclusion of the transaction. Tsuman and an unidentified male left the store and loaded the flooring into the tan Sprinter van.

At 4:27 p.m., Volodymyr Tsuman and the unidentified male arrived at the Home Depot store located at 11616 Aurora Ave N, Seattle, King County, Washington. They entered with no merchandise and Tsuman was carrying some paperwork in his hand. Approximately 10 minutes later they would emerge on camera with a cart loaded with 25 cases of Home Decorator’s Collection flooring. Tsuman approached the self-checkout register and showed the cashier the paperwork. He scanned two containers of floor putty and a box of trash bags, paying $48.45 using the Visa ending in 4004. Tsuman did not pay for any of the flooring on the cart. Tsuman and the male exited the store with the stolen flooring. Tsuman loaded the stolen flooring into the tan Sprinter Van and departed. Total loss to the store was $1550.97.

Theft 38 - On June 14, 2024, at approximately 5:56 p.m., approximately an hour and a half after leaving the Aurora Ave N store, Volodymyr Tsuman and the same male arrived at the Home Depot store located at 18333 120th Ave NE, Bothell, King County, Washington. They entered through the lumber exit with no merchandise. Tsuman was carrying paperwork in his hand. Tsuman and the male would emerge on camera with a cart loaded with 25 cases of Home Decorator’s Collection flooring. Tsuman approached a cashier and showed them the paperwork. He would purchase five buckets, paying $24.68, and put them on the Visa card ending in 4004. Tsuman did not pay for any of the flooring on the cart. Tsuman and male exited the store and went to the tan Sprinter van. Total loss to the store was $1550.97.

Theft 39 - On June 14, 2024, earlier in the day at approximately 10:35 a.m., Volodymyr Tsuman made a legitimate purchase of merchandise at the Home Depot store located at 18333 120th Ave NE Bothell, King County, WA. Tsuman put a 12-pack of caulk, twenty-two sacks of Levelquik underlayment, a pack of masking tape and a roll of red rosin paper on a carry-out order tied to the Veniamin Tsuman Pro Account. $717.14 was charged to the Visa ending in 0030 in Ben Tsuman's name. The cashier handed Volodymyr Tsuman paperwork at the conclusion of the transaction. He and the same unidentified male seen throughout the day exited the store with the merchandise and loaded it into the tan Sprinter van.

After perpetrating the theft of 25 cases of flooring totaling $1550.97, minutes before, Volodymyr Tsuman re-entered the Bothell Home Depot via the main entrance at 6:13 p.m., with no merchandise, yet paperwork in hand. Tsuman appeared on video with a cart loaded with the same items as what he had purchased at the store at 10:35 a.m. earlier that day. Tsuman approached the self-checkout register and showed the cashier managing those registers his paperwork. Tsuman would scan and pay for two Red Bulls and a pack of vacuum filters, which totaled $46.65. He did not pay for the other items on the cart. Tsuman exited the store with the stolen merchandise and proceeded to the tan Sprinter van. The male was still loading the flooring into the van. Tsuman unloaded his cart into the van as well. The total loss for the store for this theft was $717.14. The total loss to the store combined is $2268.11.

Theft 40 - On June 15, 2024, at approximately 9:22 a.m., Veniamin Tsuman arrived in a white Sprinter van at the Home Depot store located at 11915 Hwy 99, Everett, Snohomish County, Washington. He entered the store with no merchandise. Veniamin Tsuman would emerge from the appliance aisle with a shopping cart containing five cases of Home Decorator’s Collection flooring. He approached the self-checkout register and scanned only one case of the flooring, paying a total of $65.39. He utilized the Visa card ending in 0030 for the transaction. Veniamin Tsuman didn’t pay for the other four cases of flooring and left the store with the stolen merchandise. Total loss to the store was $236.72.

Theft 41 - On June 19, 2024, at approximately 6:56 p.m., Veniamin Tsuman was at the Home Depot store located at 11915 Hwy 99, Everett, Snohomish County, Washington. Veniamin Tsuman approached the customer service desk and put 42 16 ft. 2x6’s on a carry-out order tied to his Pro Account. $465.49 was charged to the Visa ending in 0030 in his (Ben) Tsuman's name. The cashier handed him paperwork at the conclusion of the transaction. An unidentified male not seen in previous incidents exited the store via the main entrance with the load of lumber he and Veniamin brought to the service desk. Less than a minute later, Veniamin Tsuman retrieved a second cart loaded with another 42 2x6’s from inside the store. He exited the store via the lumber exit without paying for the second cart, bypassing all points of sale. Tsuman left driving a white Mercedes Sprinter Van which didn’t have a license plate attached. A second white Sprinter Van, with WA CJK5762 plate attached, followed loaded with the lumber. A white male in a white T-shirt was driving the second van. Total loss to the store was $465.49.

Theft 42 - On June 24, 2024, at approximately 8:54 p.m., Volodymyr Tsuman arrived at the Home Depot store located at 9310 Quil Ceda Blvd., Marysville, Snohomish County, Washington. Volodymyr Tsuman approached the customer service desk and put a pack of Owens Corning shingles, two tubes of caulk, a box of Husky contractor bags, a pack of masking tape and a role of roof felt on a carryout order tied to the Veniamin Tsuman Pro Account. $131 .64 was charged to the Visa ending in 0030 in Ben Tsuman's name. The cashier handed Volodymyr Tsuman paperwork at the conclusion of the transaction. (Comment: Volodymyr Tsuman had twelve packs of shingles on the cart but only was charged for one of them. This appears to be a mistake on cashier's part.) Tsuman exited the store and loaded the merchandise into the tan Sprinter van. Tsuman would re-enter the store via the main entrance with no merchandise but carried paperwork with him. Tsuman would emerge from an aisle with another cartload of twelve packs of Owens Corning shingles valued at $41 .97 each, another roll of roof felt valued at $34.63, another box of Husky contractor bags valued at $29.97 and several smaller items. Tsuman approached the self-checkout register with the cartload of merchandise and scanned a bottle of Krystal Kleer windshield washer fluid, two cans of Great Stuff gap filler foam, a box of HDX trash bags and a Red Bull. He paid $39.37 using the Visa ending in 4004. Tsuman did not scan any of the shingles, roof felt or Husky contractor bags on the cart. Tsuman exited the store with the stolen merchandise, loaded it in the tan Sprinter van and left. Total loss to the store was $568.24.

Theft 43 - On July 1, 2024, at approximately 1:04 p.m., Volodymyr Tsuman arrived at the Home Depot store located at 18333 120th Ave NE, Bothell, King County, Washington. Tsuman approached the customer service desk and put five 8-packs of 8 ft. x 2 in wide baseboard, an 8-pack of 8 ft. x 5 in wide baseboard, two rolls of flooring protection, twelve sacks of Levelquick underlayment, three buckets and two rolls of Scotch blue tape on a carry-out order tied to the Veniamin Tsuman Pro Account. $758.29 was charged to the Visa ending in 0030 in Ben Tsuman's name. The cashier handed Volodymyr Tsuman paperwork at the conclusion of the transaction. Tsuman and a second white male, who would later be identified as Leonid Trotskovets, exited the store with the purchased merchandise and loaded it in the tan Sprinter van.

Approximately seven minutes later at 1:12 p.m., Trotskovets would re-enter the store via the main entrance pushing a cart. Four minutes later, Tsuman would re-enter the store via the lumber entrance. Neither had any merchandise when they re-entered. Approximately eight minutes later they would both emerge from the lumber aisle with a second cart loaded with similar merchandise. Tsuman approached a register and purchased a box of diesel exhaust fluid and two Nos energy drinks, paying $25.17 in cash. Tsuman did not pay for any of the other merchandise on the cart. Tsuman and Trotskovets exited the store with the stolen merchandise and loaded it in the tan Sprinter van. The stolen cart of merchandise had five 12 ft. packs of trim valued at $89.97 each, in place of the five packs of trim valued at $33.84 on the original order. Total loss to the store was $1018.94.

Theft 44 - On July 1, 2024, at approximately 7:51 p.m., Home Depot Asset Protection Specialist Ryan Leggott was working at the Home Depot store located at 2901 184th St. SW, Lynnwood, Snohomish County, Washington. Leggott recognized Volodymyr Tsuman and Leonid Trotskovets as suspects in a series of thefts being investigated by Home Depot. Tsuman and Trotskovets had finished selecting merchandise and were walking a cart of merchandise up to the front of the store. The cart was loaded with 12 boxes of Lifeproof Flooring, one 4.5-gallon tub of Beadex Compound, 2 bags of 80Ib mortar mix, and 1 jug of Sika Underlayment Primer. They approached the front of the store and stopped at a register. They selected a case of water and started a transaction at the register. Tsuman advised cashier Amanuel Wolde to only scan the Beadex and water, as the rest had been paid for previously. Tsuman showed Wolde a piece of paper as proof of purchase for the flooring, mortar and primer. Tsuman paid cash for the water and Beadex and exited the store, bypassing all points of sale without attempting to pay for the other items. Tsuman and Trotskovets loaded the merchandise into a vehicle and left the property. Leggott contacted Wolde who stated the paperwork he was shown displayed the correct merchandise, but he did not check the sales date or what store the paperwork was from.

Leggott reviewed the video footage of this incident. CCTV footage showed Tsuman and Trotskovets drive onto the property and enter the store without merchandise. Leggott noted Tsuman was holding paperwork in his hand at the time. They made their way to the Lifeproof Flooring and began placing items on their cart. They then proceeded to the lumber department and mortar aisle. While reviewing video, Leggott noted at no time did the two attempt to pay for the flooring, mortar mix and underlayment primer. Leggott checked store sales records for the day, which showed there were no sales for those products that day. Leggott also checked Tsuman's ProXtra account, and observed there was only 1 purchase made on his account that day, at the Bothell Home Depot, for underlayment and molding. Based on this, Leggott inventoried $821.58 in merchandise as stolen by Tsuman and Trotskovets.

Theft 45 - On July 9, 2024, at approximately 6:40 p.m., Volodymyr Tsuman and Leonid Trotskovets were at the Home Depot store located at 7345 Delridge Way SW, Seattle, King County, Washington. Tsuman approached the customer service desk and put 20 cases of Lifeproof flooring on a carry-out order tied to the Veniamin Tsuman Pro Account. $1444.92 was charged to the Visa ending in 0030 in Ben Tsuman's name. The cashier handed Volodymyr Tsuman paperwork at the conclusion of the transaction. Within seconds of the transaction being complete, Tsuman handed the cart of flooring off to Trotskovets. Trotskovets exited the store with the purchased cart of flooring as Tsuman proceeded into the lighting section with the transaction paperwork. Approximately two minutes later, Tsuman would emerge from the lumber aisle with another cart loaded with 20 cases of Lifeproof flooring. Tsuman proceeded to the lumber exit with the cartload of unpaid flooring and briefly showed paperwork to the cashier manning register 1, who was helping another customer at the time. Tsuman exited the store with the stolen flooring. Tsuman proceeded to the tan Sprinter van and loaded the stolen flooring into the Sprinter van while Trotskovets finished loading the purchased flooring. They left the property after that. Total loss to the store was $1444.92.

Theft 46 - On July 10, 2024, at approximately 2:47 p.m., Volodymyr Tsuman and Leonid Trotskovets entered the Home Depot store located at 2701 Utah Ave. S., Seattle, King County, Washington. Both entered the store with no merchandise and proceeded to the lumber section. Tsuman had paperwork in his hand. Tsuman and Trotskovets would emerge from the lumber aisle with a cart loaded with 20 cases of Lifeproof flooring and a second cart loaded with a pack of trim and smaller unidentifiable items. Tsuman approached the self-checkout register, scanned and paid for a case of bottled water and two Red Bulls, paying $13.62 using the Visa ending in 4004. Tsuman did not pay for any of the merchandise on the carts. While Tsuman was finishing the transaction, Trotskovets exited the store with the 20 cases of flooring which hadn’t been paid for. Total loss for the flooring was $1444.92. When finished, Tsuman exited the store with the pack of trim and smaller items which couldn’t be identified. The loss for the pack of the trim was $89.97. Tsuman and Trotskovets loaded the stolen merchandise into the tan Sprinter van and left the property. Total loss to the store was $1534.89.

Theft 47 - On July 12, 2024, at approximately 6:12 p.m., Veniamin Tsuman was at the Home Depot store located at 9310 Quil Ceda Blvd., Marysville, Snohomish County, Washinton. Veniamin Tsuman approached the customer service desk and put 6 4x4 posts, a box of deck screws, 6 sheets of foam board and two boxes of string lights on a carry-out order tied to his Pro Account. $662.36 was charged to the Visa ending in 0030 in his (Ben) Tsuman's name. The cashier handed Veniamin Tsuman paperwork at the conclusion of the transaction. Tsuman exited the store via the main entrance with the merchandise he just paid for and loaded it into a white Sprinter van. Four minutes later, Tsuman would re-enter the store via the lumber entrance with no merchandise but carrying paperwork. He would proceed up the lumber aisle. Tsuman would appear on CCTV from the blinds aisle with a cart loaded with similar items he had purchased a little more than 30 minutes prior. In addition to the items, there were four more boxes of string lights loaded on the cart valued at $49.97 apiece. Tsuman proceeded to the self-checkout registers and handed paperwork to the cashier. After the cashier looked over the paperwork, Tsuman exited the store without paying for any of the merchandise. He loaded the stolen merchandise into the Sprinter van and left the property. Total loss to the store was $862.24.

Theft 48 - On July 13, 2024, at approximately 9:06 a.m., Volodymyr Tsuman and Leonid Trotskovets were at the Home Depot store located at 2901 184th St. SW, Lynnwood, Snohomish County, Washington. Tsuman approached the customer service desk and put 23 sacks of Levelquik underlayment and two rolls of tape on a carry-out order tied to the Veniamin Tsuman Pro Account. $674.11 was charged to the Visa ending in 0030 in Ben Tsuman's name. The cashier handed Volodymyr Tsuman paperwork at the conclusion of the transaction. When the transaction was done, Tsuman assisted Trotskovets out the main entrance with the purchased merchandise. Tsuman then proceeded into the paint aisle carrying the paperwork from the transaction he just completed. Trotskovets continued to the tan Sprinter van and loaded the merchandise inside. Four minutes later Tsuman appeared from the lumber aisle with a second cart loaded with 23 sacks of Levelquik underlayment and two packs of tape. A minute later, Tsuman approached a register with this cart and showed the cashier the paperwork. Tsuman purchased two Red Bull energy drinks, and a screwdriver set, paying $19.17 using the Visa ending in 4004. He did not pay for any of the underlayment or tape on the cart. Tsuman exited the store and loaded the stolen merchandise in the tan Sprinter van. Total loss to the store was $674.11.

Theft 49 - On July 13, 2024, at approximately 3:22 p.m., roughly six hours after the theft at the Lynwood Home Depot, Volodymyr Tsuman entered the Home Depot store located at 9310 QuiI Ceda Blvd., Marysville, Snohomish County, Washington. Tsuman entered the store via the main entrance with no merchandise yet carrying paperwork. At 3:35 p.m., approximately 13 minutes later, Tsuman would emerge from the lumber aisle with a cart load of merchandise (23 sacks of Levelquik and two rolls of tape) matching what he purchased at the Lynwood Home Depot earlier in the day. Tsuman approached a register and purchased a bucket. He motioned to the paperwork that was situated between two packs of tape, but the cashier did not check the paperwork. Tsuman paid $4.89 for the bucket using the Visa ending in 4004. Tsuman did not pay for any of the Levelquik underlayment or tape on the cart. He exited the store with the merchandise and left the property. Total loss to the store is $674.11.

Theft 50 - On July 14, 2024, at approximately 7:18 a.m., Veniamin Tsuman entered the Home Depot store located at 9310 Quil Ceda Blvd., Marysville, Snohomish County, Washington. He did not have anything in his hands when he entered and walked up the lumber aisle. Tsuman would appear exiting the garden section with four potted plants and four cinder blocks. He scanned two of the four potted plants and two small roles of rope, paying $107.64 using the Visa ending in 0030. Tsuman exited the store with two plants and four cinder blocks which he didn’t pay for valued at $83.84. Tsuman loaded the stolen and purchased merchandise into the white Sprinter Van and re-entered the store with an empty cart. He would emerge from the flooring aisle with four rugs. He proceeded to the self-checkout and scanned one of the four rugs, an energy drink and a candy bar, paying $61.28 using the Visa ending in 0030. Tsuman exited the store with the merchandise he paid for, and three rugs he didn’t pay for. He loaded the stolen and purchased merchandise into the Sprinter van and left the property. The store loss store loss was $147.92. The total loss to the store was $231.26.

Theft 51 - On July 16, 2024, at approximately 1:15 p.m., Volodymyr Tsuman and Leonid Trotskovets arrived at the Home Depot store located at 18333 120th Ave NE, Bothell, King County, Washington in the tan Sprinter van. They entered the store through the lumber entrance with no merchandise in hand. The two would make their way to the flooring department. Tsuman and Trotskovets would proceed to load 20 bags of underlayment, 2 rolls of tape, 1 Glacier Bay faucet/shower combo, 1 Kohler Faucet Basin, and 2 boxes of Lifeproof flooring (valued at $1197.26 after discounts) onto a cart. With the merchandise they approached the Pro desk. Tsuman conducted a phone sale transaction for the merchandise. Prior to Tsuman receiving paperwork for the transaction, Trotskovets exited the store with the merchandise through the lumber exit. After receiving the purchase receipt, Tsuman went back into the store aisles and loaded a cart with nearly identical merchandise to what was paid for and that Trotskovets left with. Tsuman selected 20-21 bags of Underlayment, 2 6-packs of scotch tape, 1 Pfister Faucet/shower combo, 1 unknown faucet (not stolen), 1 Elkay Faucet Basin, and 2 boxes of Lifeproof flooring. Tsuman went to the front of the store to the Returns Exit. Tsuman stopped near the returns registers and retrieved the faucet, appearing as if he was going to speak to a cashier. Tsuman waited for a short time, then put the faucet down, retrieved the cart and exited the store without paying for the merchandise on the cart. Tsuman would contact Trotskovets at the Sprinter van and hand the cart off to him. Totskovets loaded the second cart of merchandise into the van. Tsuman re-entered the store and purchased two Red Bulls and a case of water at the self-checkout. Tsuman exited the store, returned to the van, and he and Trotskovets left the property. Home Depot Asset Protection Specialist Ryan Leggott reviewed the CCTV footage and checked the sales records. He confirmed Tsuman didn’t pay for any of the merchandise he loaded onto the second cart prior to exiting the store. Leggott confirmed Tsuman walked out with 20 bags of LevelQuik Underlayment, 2 6-pack packages of Scotch Tape, 1 Pfister Faucet/Shower Combo, 1 Elkay Faucet Basin, and 2 boxes of life proof flooring. He calculated the total loss to the store was at least $1148.18.

Attempted Theft – Arrest of Volodymyr Tsuman - On July 16, 2024, Leggott was working with Asset Protection Specialist Nicholas Lang at the Home Depot store located at 2901 184th St. SW, Lynnwood, Snohomish County, Washington. Leggott was patrolling the floor at approximately 3:25 p.m., which was approximately an hour and fifteen minutes after Tsuman and Trotskovets left the Bothell store. Leggott observed Tsuman and Trotskovets already inside the Lynwood store in the lumber department with a cart loaded with Beadex jugs and drywall. Leggott observed Tsuman and Trotskovets make their way to the insulation aisle and begin loading insulation onto the cart. Trotskovets retrieved a second cart and brought it to the drywall aisle. Tsuman and Trotskovets loaded the second cart with the same amount of Beadex and drywall as the first cart. Tsuman and Trotskovets then returned to the first cart. Tsuman and

Trotskovets moved the first cart to the plumbing department and selected a water heater and supplies. They moved this cart to the front of the store and up to the service desk. Tsuman requested to conduct a phone sale for the cart they had with them, making no mention of the second cart they loaded with Beadex and drywall. When the phone sale was complete, Totskovets exited the store with the purchased merchandise. Tsuman kept the paperwork for the transaction and went back into the store, contacting the second cart they loaded with Beadex and drywall. Tsuman retrieved the cart and proceeded to the insulation aisle, where it appeared he began using the receipt to select the identical amount of insulation and placing it on the cart.

Leggott believed Tsuman was going to walk out without paying for the merchandise on the cart as this is what he has been known to do by Home Depot employees. Lang contacted law enforcement to report the activity. Tsuman began pacing the store and looking around behind him, ultimately abandoning the second cart in the insulation aisle. Tsuman exited the store without the cart, contacted Trotskovets at the van and helped him load the purchased merchandise.

Leggott met with responding Lynwood PD Officer McDonald, who arrived, and provided him a verbal statement of what happened. Leggott advised Officer McDonald of the July 1st incident, this day’s attempted theft, and Tsuman’s history. Leggott would provide information on the known theft incidents, CCTV for the July 1st Incident, photos, and the ORC Packet that Home Depot ORC Investigator Ryan Lemmers provided Leggott. Leggott also showed Officer McDonald the cart of merchandise Tsuman left in the store. Based on the information Officer McDonald learned, he felt probable cause existed to arrest Volodymyr Tsuman for Organized Retail Theft 1st, which he did. Lynwood Police Department Officer Anthony had previously used a language line to read Tsuman his Miranda Warnings and conduct an interview. Officer McDonald spoke to Tsuman with the assistance of the language line to explain the reason for being arrested. MacDonald was able to have a conversation without the use of the language line after that. While searching Tsuman incident to arrest, he located numerous receipts from Home Depot transactions. The receipts were taken for evidence. Tsuman was identified by his Washington State Driver’s license.

Trotskovets was contacted and requested to exit the van by a LPD officer. Through use of the language line officers were able to advise Trotskovets of his Miranda Warnings and positively identify him. Trotskovets was advised he would be released that day but may be charged with a crime later.

Officers impounded Tsuman’s van and obtained a search warrant. Pursuant to the warrant authorized by Judge Bouffiou, officers searched the tan Sprinter van and located multiple Home Depot receipts, Home Depot products, and a cell phone belonging to Volodymyr Tsuman.

Theft 52 - On July 16, 2024, at approximately 7:08 p.m., Veniamin Tsuman entered the Home Depot store located at 9310 Quil Ceda Blvd., Marysville, Snohomish County, Washington. Veniamin Tsuman wasn’t carrying anything with him and retrieved a cart. Tsuman emerged from the paint aisle with 20 sacks of Levelquik underlayment. He proceeded to a self-checkout register and scanned and paid for eight of the sacks on the cart. He paid $253.40 using the Visa ending in 0030. Tsuman exited the store without paying for the other 12 sacks of Levelquik and loaded them into a Sprinter van. Following the theft, Tsuman stayed at the store and conducted three more transactions, but committed no other thefts. Tsuman would eventually leave the store. Total loss to the store for the 12 sacks of Levelquik was $347.76.

When Volodymyr Tsuman was arrested on July 16th by Lynwood Police, he was searched incident to his arrest. During the search officers located numerous Home Depot receipts. Those receipts were photographed as part of the investigation. The receipts were compared to the known transactions/thefts Tsuman conducted in Lemmers report. Two receipts dated July 1, 2024, and time stamped at 5:41 p.m. and 8:36 p.m. respectively, were not documented in the report. This information was provided to Lemmers, and he was able to confirm these were two thefts which were unknown to him. Lemmers would provide a supplemental report in reference to these two thefts which included video and still photos. They are documented as follows.

Theft 53 - On July 1, 2024, at approximately 1:04 p.m., Volodymyr Tsuman and Leonid Trotskovets were at the Home Depot store located at 18333 120th Ave NE, Bothell, King County, Washington. Tsuman purchased three buckets, five 8-packs of 8 ft. x 2 in wide baseboard, an 8-pack of 8 ft. x 5 in wide baseboard, two rolls of flooring protection, twelve sacks of Levelquick underlayment and two rolls of Scotch blue tape on a carry-out order tied to the Veniamin Tsuman Pro Account. $758.29 was charged to the Visa ending in 0030 in Ben Tsuman’s name. The cashier handed Volodymyr Tsuman paperwork at the conclusion of the transaction. Tsuman and Trotskovets exited the store with the purchased merchandise. Later that same day, at 5:21 p.m., they returned to the Bothell Home Depot store. Tsuman and Trotskovets approached a register with similar items to those they legitimately purchased at 1:04 p.m. Tsuman showed the cashier paperwork, and paid for two sacks of Sakrete mortar, a box of diesel exhaust fluid and a box of trash bags. Tsuman paid $58.37 in cash for those items but was not charged for the other items on the carts. Tsuman and Trotskovets exited the store with the stolen merchandise, loaded it in the tan Sprinter van and left the property. Total loss to the store was $758.29.

Theft 54 - On July 1, 2024, at approximately 8:37 p.m., Volodymyr Tsuman was at the Home Depot store located at 11915 Hwy 99, Everett, Snohomish County, Washington. He entered with no merchandise in his hands. Tsuman approached the self-check-out register with a cart containing twelve cases of Lifeproof flooring, two sacks of self-leveling compound, a gallon of Sika concrete adhesive, a pack of paper towels and a drain opener. Tsuman purchased the paper towels and drain opener, paying $51.34 in cash. Tsuman did not pay for any of the remaining merchandise on the cart. As Tsuman was leaving he was approached by a cashier. Tsuman motioned to paperwork on top of the flooring. The cashier inspected the paperwork and allowed Tsuman to exit the store. Tsuman pushed the cartload of stolen merchandise out of camera view. The tan Sprinter van exited the property approximately seven minutes later. Total loss to the store was $863.28.

Home Depot ORC Investigator Ryan Lemmers calculated the total inventory lost as a result of the above 52 thefts and determined that Home Depot suffered a loss of $47,260.96. With the additional two thefts found after the arrest of Tsuman the total rises to $48,878.47.

Based on the above facts and circumstances, probable cause exists that Volodymyr Tsuman committed the offense of Organized Retail Theft 1st degree by committing 46 thefts totaling $44,775.41 over a four-month period against Home Depot stores in Snohomish, King, Pierce, and Thurston counties. Probable cause also exists that Veniamin Tsuman committed the offense of Organized Retail Theft 2nd degree, as he committed eight thefts over the same four-month period totaling $4,103.06 in Snohomish and King Counties. Additionally, probable cause exists that Leonid Trotskovets as an accomplice with Volodymyr Tsuman, committed the offense of Organized Retail Theft 1st by committing seven thefts over a two-week span in July 2024 in King and Snohomish Counties totaling $7400.91. I am requesting charges be filed against each individual.

Signed and dated by me this 21st day of November, 2024, at Seattle, Washington.

Matthew Harschfeld

Investigator

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