* Count 23: Sanja Elliott, on a date unknown between February 1, 2016 and December 31, 2016, with intent to defraud, obtained the sum of $400,000 from the Manchester Parish Council by falsely pretending that the said monies were bona fide payments for work done by TM on behalf of the Manchester Parish Council.

* Count 25: Sanja Elliott, on a date unknown between December 1, 2015 and December 31, 2015 with intent to defraud, obtained the sum of $300,000 from the Manchester Parish Council by falsely pretending that the said monies were bona fide payments for work done by MM on behalf of the Manchester Parish Council.

* Count 26: Sanja Elliott, on dates unknown between January 1, 2015 and December 31, 2016 in the parish of Manchester, with intent to defraud, obtained in excess of $1,000,000 from the Manchester Parish Council by falsely pretending that the said monies were bona fide payments for work done by NH on behalf of the Manchester Parish Council.

From the evidence of these witnesses as well as the payment vouchers and invoices admitted in evidence, the court can draw reasonable inferences that Mr Elliott obtained money from the council by falsely pretending that these individuals were legitimate contractors who had performed bona fide work for the council, as described in the respective payment vouchers and invoices, and were thus entitled to payment.

[191] The Crown invites the court to find that Mr Elliott, by certifying the payment vouchers and invoices, dishonestly represented to the council that sums were owed to TM, MM and NH for bona fide work performed.