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Felony Complaint vrs. Siringoringo et all

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    SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINOSAN BERNARDINO JUSTICE CENTER DISTRICT

    THE PEOPLE OF THE STATE OF CALIFORNIA,

    Plaintiff

    vs.

    Stephen Lyster Siringoringo , Alfred O. Clausen ,Joshua Michael Cobb

    Defendant

    ))))))))))))) 

    COURT CASE NO

    FELONY COMPLAINT

    DA CASE NO 2014-00-0037288

    The undersigned is informed and believes that:

    COUNT 1

    On or about January 23, 2013 through July 29, 2013, in the above named judicial district,

    the crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION

    487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua

    Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine

    Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Everado Rincon .It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

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      It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 47,48,49,50,51,52,53,54,55,56,57,58,59,60,61,62,63,64,65,66,67,68,69,70,71 are

    related felonies, a material element of which is fraud and embezzlement, which involve a pattern of

    related felony conduct, and the pattern of related felony conduct involves the taking of more than

    one hundred thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 2

    On or about January 23, 2013 through July 29, 2013, in the above named judicial district,

    the crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN

    MODIFICATION, in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by

    Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform

    a residential mortgage loan modification for a mortgage and/or deed of trust secured by residential

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    real property containing four or fewer dwelling units, for a fee or compensation paid by the

    borrower, and did willfully and unlawfully demand and/or receive preperformance compensation.

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 3

    On or about March 6, 2013 through July 29, 2013, in the above named judicial district, the

    crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION

    487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua

    Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine

    Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Rolando Antonio

    Hernandez .

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

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    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

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    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 4

    On or about March 6, 2013 through July 29, 2013, in the above named judicial district, the

    crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,

    in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster

    Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential

    mortgage loan modification for a mortgage and/or deed of trust secured by residential real property

    containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did

    willfully and unlawfully demand and/or receive preperformance compensation.

    *****

    COUNT 5

    On or about December 14, 2012 through July 29, 2013, in the above named judicial district,

    the crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION

    487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua

    Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine

    Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Patricio Mendoza .

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

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      It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 6

    On or about December 14, 2012 through July 29, 2013, in the above named judicial district,

    the crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN

    MODIFICATION, in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by

    Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform

    a residential mortgage loan modification for a mortgage and/or deed of trust secured by residential

    real property containing four or fewer dwelling units, for a fee or compensation paid by the

    borrower, and did willfully and unlawfully demand and/or receive preperformance compensation.

    *****

    COUNT 7

    On or about June 24, 2011 through July 29, 2013, in the above named judicial district, the

    crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION

    487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua

    Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine

    Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Emilio C. Magdaleno .

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

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    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 8

    On or about June 24, 2011 through July 29, 2013, in the above named judicial district, the

    crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,

    in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster

    Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential

    mortgage loan modification for a mortgage and/or deed of trust secured by residential real property

    containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did

    willfully and unlawfully demand and/or receive preperformance compensation.

    *****

    COUNT 9

    On or about May 6, 2013 through July 29, 2013, in the above named judicial district, the

    crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION

    487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua

    Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine

    Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Manuel Villalpando .

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

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    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 12

    On or about August 31, 2012 through July 29, 2013, in the above named judicial district, the

    crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,

    in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster

    Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential

    mortgage loan modification for a mortgage and/or deed of trust secured by residential real property

    containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did

    willfully and unlawfully demand and/or receive preperformance compensation.

    *****

    COUNT 13

    On or about May 21, 2013 through July 29, 2013, in the above named judicial district, the

    crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION

    487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua

    Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine

    Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Elias Salazar .

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      It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 14

    On or about May 21, 2013 through July 29, 2013, in the above named judicial district, the

    crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,

    in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster

    Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential

    mortgage loan modification for a mortgage and/or deed of trust secured by residential real property

    containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did

    willfully and unlawfully demand and/or receive preperformance compensation.

    *****

    COUNT 15

    On or about July 17, 2013 through July 29, 2013, in the above named judicial district, the

    crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION

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    487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua

    Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine

    Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Martha Hernandez .

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 16

    On or about July 17, 2013 through July 29, 2013, in the above named judicial district, the

    crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,

    in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster

    Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential

    mortgage loan modification for a mortgage and/or deed of trust secured by residential real property

    containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did

    willfully and unlawfully demand and/or receive preperformance compensation.

    *****

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      COUNT 17

    On or about February 24, 2013 through July 29, 2013, in the above named judicial district,

    the crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION

    487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua

    Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine

    Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Lidia Osuma .

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 18

    On or about February 24, 2013 through July 29, 2013, in the above named judicial district,

    the crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN

    MODIFICATION, in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by

    Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform

    a residential mortgage loan modification for a mortgage and/or deed of trust secured by residential

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    real property containing four or fewer dwelling units, for a fee or compensation paid by the

    borrower, and did willfully and unlawfully demand and/or receive preperformance compensation.

    *****

    COUNT 19

    On or about July 18, 2012 through July 29, 2013, in the above named judicial district, the

    crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION

    487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua

    Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine

    Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Ramon Cano Rodriguez .

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 20

    On or about July 18, 2013 through July 29, 2013, in the above named judicial district, the

    crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,

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      COUNT 22

    On or about February 6, 2013 through July 29, 2013, in the above named judicial district,

    the crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN

    MODIFICATION, in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by

    Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform

    a residential mortgage loan modification for a mortgage and/or deed of trust secured by residential

    real property containing four or fewer dwelling units, for a fee or compensation paid by the

    borrower, and did willfully and unlawfully demand and/or receive preperformance compensation.

    *****

    COUNT 23

    On or about March 26, 2012 through July 29, 2013, in the above named judicial district, the

    crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION

    487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua

    Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine

    Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Wanderlei B De Oliveria .

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

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    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 24

    On or about March 26, 2012 through July 29, 2013, in the above named judicial district, the

    crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,

    in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster

    Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential

    mortgage loan modification for a mortgage and/or deed of trust secured by residential real property

    containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did

    willfully and unlawfully demand and/or receive preperformance compensation.

    *****

    COUNT 25

    On or about August 27, 2012 through July 29, 2013, in the above named judicial district, the

    crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION

    487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua

    Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine

    Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Oslett Antone .

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

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    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 28

    On or about May 22, 2013 through July 29, 2013, in the above named judicial district, the

    crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,

    in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster

    Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential

    mortgage loan modification for a mortgage and/or deed of trust secured by residential real property

    containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did

    willfully and unlawfully demand and/or receive preperformance compensation.

    *****

    COUNT 29

    On or about July 16, 2012 through July 29, 2013, in the above named judicial district, the

    crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION

    487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua

    Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine

    Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Richard Hernandez .

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

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      It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 30

    On or about July 16, 2012 through July 29, 2013, in the above named judicial district, the

    crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,

    in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster

    Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential

    mortgage loan modification for a mortgage and/or deed of trust secured by residential real property

    containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did

    willfully and unlawfully demand and/or receive preperformance compensation.

    *****

    COUNT 31

    On or about June 27, 2012 through July 29, 2013, in the above named judicial district, the

    crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION

    487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua

    Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine

    Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Diana M. Stanfield .

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

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    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 32

    On or about June 27, 2012 through July 29, 2013, in the above named judicial district, the

    crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,

    in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster

    Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential

    mortgage loan modification for a mortgage and/or deed of trust secured by residential real property

    containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did

    willfully and unlawfully demand and/or receive preperformance compensation.

    *****

    COUNT 33

    On or about July 4, 2013 through July 4, 2013, in the above named judicial district, the

    crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION

    487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua

    Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine

    Hundred Fifty Dollars ($950), to wit cash in the amount of the property of George Alexander .

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      It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 34

    On or about July 4, 2013 through July 4, 2013, in the above named judicial district, the

    crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,

    in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster

    Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential

    mortgage loan modification for a mortgage and/or deed of trust secured by residential real property

    containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did

    willfully and unlawfully demand and/or receive preperformance compensation.

    *****

    COUNT 35

    On or about March 26, 2012 through July 29, 2013, in the above named judicial district, the

    crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION

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    487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua

    Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine

    Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Mercedes Caamal .

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 36

    On or about March 26, 2012 through July 29, 2013, in the above named judicial district, the

    crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,

    in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster

    Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential

    mortgage loan modification for a mortgage and/or deed of trust secured by residential real property

    containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did

    willfully and unlawfully demand and/or receive preperformance compensation.

    *****

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      COUNT 37

    On or about July 19, 2012 through July 29, 2013, in the above named judicial district, the

    crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION

    487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua

    Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine

    Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Maria F Resto .

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 38

    On or about July 19, 2012 through July 29, 2013, in the above named judicial district, the

    crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,

    in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster

    Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential

    mortgage loan modification for a mortgage and/or deed of trust secured by residential real property

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    containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did

    willfully and unlawfully demand and/or receive preperformance compensation.

    *****

    COUNT 39

    On or about July 1, 2012 through July 29, 2013, in the above named judicial district, the

    crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION

    487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua

    Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine

    Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Gloria Barajas .

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 40

    On or about July 1, 2012 through July 29, 2013, in the above named judicial district, the

    crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,

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    in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster

    Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential

    mortgage loan modification for a mortgage and/or deed of trust secured by residential real property

    containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did

    willfully and unlawfully demand and/or receive preperformance compensation.

    *****

    COUNT 41

    On or about June 1, 2012 through July 29, 2013, in the above named judicial district, the

    crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION

    487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua

    Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine

    Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Celia Marquez .

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

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      COUNT 42

    On or about June 1, 2012 through July 29, 2013, in the above named judicial district, the

    crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,

    in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster

    Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential

    mortgage loan modification for a mortgage and/or deed of trust secured by residential real property

    containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did

    willfully and unlawfully demand and/or receive preperformance compensation.

    *****

    COUNT 43

    On or about May 29, 2013 through May 29, 2013, in the above named judicial district, the

    crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION

    487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua

    Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine

    Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Ronald Sweatt .

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

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    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 44

    On or about May 29, 2013 through May 29, 2013, in the above named judicial district, the

    crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,

    in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster

    Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential

    mortgage loan modification for a mortgage and/or deed of trust secured by residential real property

    containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did

    willfully and unlawfully demand and/or receive preperformance compensation.

    *****

    COUNT 45

    On or about May 25, 2013 through May 25, 2013, in the above named judicial district, the

    crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION

    487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua

    Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine

    Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Gerardo Herrera Villa .

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

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      It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 46

    On or about May 25, 2013 through May 25, 2013, in the above named judicial district, the

    crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,

    in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster

    Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential

    mortgage loan modification for a mortgage and/or deed of trust secured by residential real property

    containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did

    willfully and unlawfully demand and/or receive preperformance compensation.

    *****

    COUNT 47

    On or about January 19, 2012 through January 19, 2012, in the above named judicial

    district, the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a

    felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael

    Cobb, who did unlawfully conduct and attempt to conduct a transaction involving a monetary

    instrument or instruments of a value exceeding 170,000 through a financial institution with the

    intent to promote, manage, establish, carry on, and facilitate the promotion, management,

    establishment, and carrying on of criminal activity, to wit: grand theft, and knowing that the

    monetary instrument represented the proceeds of, and was derived directly or indirectly from the

    proceeds of, criminal activity.

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

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    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 48

    On or about April 4, 2012 through April 4, 2012, in the above named judicial district, the

    crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony, was

    committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did

    unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or

    instruments of a value exceeding 240,000 through a financial institution with the intent to promote,

    manage, establish, carry on, and facilitate the promotion, management, establishment, and

    carrying on of criminal activity, to wit: grand theft, and knowing that the monetary instrument

    represented the proceeds of, and was derived directly or indirectly from the proceeds of, criminal

    activity.

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

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      It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 49

    On or about April 19, 2012 through April 19, 2012, in the above named judicial district, the

    crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony, was

    committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did

    unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or

    instruments of a value exceeding 320,000 through a financial institution with the intent to promote,

    manage, establish, carry on, and facilitate the promotion, management, establishment, and

    carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that

    the monetary instrument represented the proceeds of, and was derived directly or indirectly from

    the proceeds of, criminal activity.

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

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    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 50

    On or about May 2, 2012 through May 2, 2012, in the above named judicial district, the

    crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony, was

    committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did

    unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or

    instruments of a value exceeding 200,000 through a financial institution with the intent to promote,

    manage, establish, carry on, and facilitate the promotion, management, establishment, and

    carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that

    the monetary instrument represented the proceeds of, and was derived directly or indirectly from

    the proceeds of, criminal activity.

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

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    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 51

    On or about May 10, 2012 through May 12, 2012, in the above named judicial district, the

    crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony, was

    committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did

    unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or

    instruments of a value exceeding 180,000 through a financial institution with the intent to promote,

    manage, establish, carry on, and facilitate the promotion, management, establishment, and

    carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that

    the monetary instrument represented the proceeds of, and was derived directly or indirectly from

    the proceeds of, criminal activity.

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

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    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 52

    On or about May 17, 2012 through May 17, 2012, in the above named judicial district, the

    crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony, was

    committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did

    unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or

    instruments of a value exceeding 258,000 through a financial institution with the intent to promote,

    manage, establish, carry on, and facilitate the promotion, management, establishment, and

    carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that

    the monetary instrument represented the proceeds of, and was derived directly or indirectly from

    the proceeds of, criminal activity.

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

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      It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 53

    On or about May 21, 2012 through May 21, 2012, in the above named judicial district, the

    crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony, was

    committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did

    unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or

    instruments of a value exceeding 200,000 through a financial institution with the intent to promote,

    manage, establish, carry on, and facilitate the promotion, management, establishment, and

    carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that

    the monetary instrument represented the proceeds of, and was derived directly or indirectly from

    the proceeds of, criminal activity.

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

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    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 54

    On or about June 12, 2012 through June 12, 2012, in the above named judicial district, the

    crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony, was

    committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did

    unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or

    instruments of a value exceeding 200,000 through a financial institution with the intent to promote,

    manage, establish, carry on, and facilitate the promotion, management, establishment, and

    carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that

    the monetary instrument represented the proceeds of, and was derived directly or indirectly from

    the proceeds of, criminal activity.

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

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    *****

    COUNT 56

    On or about July 3, 2012 through July 3, 2012, in the above named judicial district, the

    crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony, was

    committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did

    unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or

    instruments of a value exceeding 200,000 through a financial institution with the intent to promote,

    manage, establish, carry on, and facilitate the promotion, management, establishment, and

    carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that

    the monetary instrument represented the proceeds of, and was derived directly or indirectly from

    the proceeds of, criminal activity.

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

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      COUNT 57

    On or about July 11, 2012 through July 11, 2012, in the above named judicial district, the

    crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony, was

    committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did

    unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or

    instruments of a value exceeding 310,000 through a financial institution with the intent to promote,

    manage, establish, carry on, and facilitate the promotion, management, establishment, and

    carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that

    the monetary instrument represented the proceeds of, and was derived directly or indirectly from

    the proceeds of, criminal activity.

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 58

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      On or about July 18, 2012 through July 18, 2012, in the above named judicial district, the

    crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony, was

    committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did

    unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or

    instruments of a value exceeding 375,000 through a financial institution with the intent to promote,

    manage, establish, carry on, and facilitate the promotion, management, establishment, and

    carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that

    the monetary instrument represented the proceeds of, and was derived directly or indirectly from

    the proceeds of, criminal activity.

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 59

    On or about July 25, 2012 through July 25, 2012, in the above named judicial district, the

    crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony, was

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    committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did

    unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or

    instruments of a value exceeding 460,000 through a financial institution with the intent to promote,

    manage, establish, carry on, and facilitate the promotion, management, establishment, and

    carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that

    the monetary instrument represented the proceeds of, and was derived directly or indirectly from

    the proceeds of, criminal activity.

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 60

    On or about August 3, 2012 through August 3, 2012, in the above named judicial district, the

    crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony, was

    committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did

    unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or

    Page 40 Complaint DA CASE NO: 2014-00-0037288 

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    instruments of a value exceeding 450,000 through a financial institution with the intent to promote,

    manage, establish, carry on, and facilitate the promotion, management, establishment, and

    carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that

    the monetary instrument represented the proceeds of, and was derived directly or indirectly from

    the proceeds of, criminal activity.

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth

    in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a

    material element of which is fraud and embezzlement, which involve a pattern of related felony

    conduct, and the pattern of related felony conduct involves the taking of more than one hundred

    thousand dollars ($100,000).

    *****

    COUNT 61

    On or about August 10, 2012 through August 10, 2012, in the above named judicial district,

    the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony,

    was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who

    did unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or

    instruments of a value exceeding 340,000 throug


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