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7/16/03 - Actual Lawsuit filed against Titles Unlimited where the future California SB-100 ruling originated from...

BILL LOCKYER - Attorney General of the State of California            SEE ACTUAL PRESS RELEASE HERE
ROBERT R. ANDERSON - Chief Assistant Attorney General
MARK O. GEIGER - Senior Assistant Attorney General
ROBERT M. MORGESTER - Deputy Attorney General
State Bar No. 142236 - 1300 I Street - P.O. Box 944255
Sacramento, CA 94244-2550 Telephone: (916) 445-9330 Fax: (916) 324-2960

Attorneys for Plaintiff
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SACRAMENTO
THE PEOPLE OF THE STATE OF CALIFORNIA,
Plaintiff,
v.
RICHARD WEAVER,
Defendant.
03FO4611
FIRST AMENDED
COMPLAINT (FELONY)

FIRST AMENDED COMPLAINT (FELONY)
BILL LOCKYER
Attorney General of the State of California
ROBERT R. ANDERSON
Chief Assistant Attorney General
MARK O. GEIGER
Senior Assistant Attorney General
ROBERT M. MORGESTER - Deputy Attorney General
State Bar No. 142236 - 1300 I Street -P.O. Box 944255
Sacramento, CA 94244-2550 - Telephone: (916) 445-9330 - Fax: (916) 323-5363

Attorneys for Plaintiff
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SACRAMENTO
THE PEOPLE OF THE STATE OF CALIFORNIA,
Plaintiff,
v.
RICHARD WEAVER,
Defendant.
03FO4611
FIRST AMENDED
COMPLAINT (FELONY)
The People of the State of California upon oath of the undersigned, upon information and
belief complain against the Defendant RICHARD WEAVER, above named for the crime(s) as
follows:

COUNT 1
(OFFER FALSE INSTRUMENTS)
In and between May 7, 2001, and May 18, 2001, atand in the County of Sacramento in the State of California, Defendant RICHARD WEAVER, did commit a felony namely a violation of SECTION 4463(A) OF THE VEHICLE CODE of the State of California, in that said Defendant did unlawfully and with intent to defraud, falsify a Certificate of Ownership and registration card to and for a motor vehicle and did utter, publish, pass, and attempt to pass the same as true and genuine, to wit Bill of Sale and vehicle registration for a 1965 Ford Cobra for
Thomas Plevin.

COUNT 2
(OFFER FALSE INSTRUMENTS)
In and between August 2, 2001, and September 13, 2001, at and in the County of Sacramento in the State of California, Defendant RICHARD WEAVER, did commit a felony, namely a violation of SECTION 4463(A) OF THE VEHICLE CODE OF THE STATE OF CALIFORNIA, in that said Defendant did unlawfully and with the intent to defraud, falsify a Certificate of Ownership and registration card to and for a motor vehicle and did utter, publish, pass, and attempt to pass the same as true and genuine, towit, Bill of Sale and vehicle registration for a 1965 Ford Cobra for
Randy Rosenburg.

COUNT 3
(OFFER FALSE INSTRUMENTS)
In and between August 1, 2000, and December 12, 2000, at and in the County of Sacramento in the State of California, Defendant RICHARD WEAVER, did commit a felony, namely a violation of SECTION 4463(A) OF THE VEHICLE CODE OF THE STATE OF CALIFORNIA, in that said Defendant did unlawfully and with the intent to defraud, falsify a Certificate of Ownership and registration card to and for a motor vehicle and did utter, publish, pass, and attempt to pass the same as true and genuine, towit, Bill of Sale and vehicle registration for a 1965 Ford for
Frank Kong.

COUNT 4
(OFFER FALSE INSTRUMENTS)
In and between January 1, 2001, and March 5, 2001, at and in the County of Sacramento, Defendant RICHARD WEAVER, did commit a felony, namely a violation of SECTION 4463(A) OF THE VEHICLE CODE OF THE STATE OF CALIFORNIA, in that said Defendant did unlawfully and with the intent to defraud, falsify a Certificate of Ownership and registration card to and for a motor vehicle and did utter, publish, pass, and attempt to pass the same as true and genuine, to wit, Bill of Sale and vehicle registration for a 1965 Ford Cobra for
Dennis Gordon.

COUNT 5
(OFFER FALSE INSTRUMENTS)
In and between January 1, 2001, and February 15, 2001, at and in the County of Sacramento, Defendant RICHARD WEAVER, did commit a felony, namely a violation of SECTION 4463(A) OF THE VEHICLE CODE OF THE STATE OF CALIFORNIA, in that said Defendant did unlawfully and with the intent to defraud, falsify a Certificate of Ownership and registration card to and for a motor vehicle and did utter, publish, pass, and attempt to pass the same as true and genuine, to wit, Bill of Sale and vehicle registration for a 1965 Ford Cobra for
Dennis Gordon.

COUNT 6
(OFFER FALSE INSTRUMENTS)
In and between September 1, 2000, and September 26, 2000, at and in the County of Sacramento, Defendant RICHARD WEAVER, did commit a felony, namely a violation of SECTION 4463(A) OF THE VEHICLE CODE OF THE STATE OF CALIFORNIA, in that said Defendant did unlawfully and with the intent to defraud, falsify a Certificate of Ownership and registration card to and for a motor vehicle and did utter, publish, pass, and attempt to pass the same as true and genuine, to wit, Bill of Sale and vehicle registration for a 1967 Ford for
Fitzroy Killingsworth.

COUNT 7
(OFFER FALSE INSTRUMENTS)
In and between May 1, 2001, and July 16, 2001, at and in the County of Sacramento, Defendant RICHARD WEAVER, did commit a felony, namely a violation of SECTION 4463(A) OF THE VEHICLE CODE OF THE STATE OF CALIFORNIA, in that said Defendant did unlawfully and with the intent to defraud, falsify a Certificate of Ownership and registration card to and for a motor vehicle and did utter, publish, pass, and attempt to pass the same as true and genuine, to wit, Bill of Sale and vehicle registration for a 1965 Ford Cobra for
Steven Spears.

COUNT 8
(OFFER FALSE INSTRUMENTS)
In and between May 1, 200, and June 28, 2000, at and in the County of Sacramento, Defendant RICHARD WEAVER, did commit a felony, namely a violation of SECTION 4463(A) OF THE VEHICLE CODE OF THE STATE OF CALIFORNIA, in that said Defendant did unlawfully and with the intent to defraud, falsify a Certificate of Ownership and registration card to and for a motor vehicle and did utter, publish, pass, and attempt to pass the same as true and genuine, to wit, Bill of Sale and vehicle registration for a 1965 Ford Cobra for
Bradley Pfeifer.

COUNT 9
(OFFER FALSE INSTRUMENTS)
In and between August 1, 2001, and April 24, 2001, at and in the County of Sacramento, Defendant RICHARD WEAVER, did commit a felony, namely a violation of SECTION 4463(A) OF THE VEHICLE CODE OF THE STATE OF CALIFORNIA, in that said Defendant did unlawfully and with the intent to defraud, falsify a Certificate of Ownership and registration card to and for a motor vehicle and did utter, publish, pass, and attempt to pass the same as true and genuine, to wit, Bill of Sale and vehicle registration for a 1965 Ford Cobra for
Daniel Nissim.

COUNT 10
(OFFER FALSE INSTRUMENTS)
In and between September 2000, and December 2000, at and in the County of Sacramento, Defendant RICHARD WEAVER, did commit a felony, namely a violation of SECTION 4463(A) OF THE VEHICLE CODE OF THE STATE OF CALIFORNIA, in that said Defendant did unlawfully and with the intent to defraud, falsify a Certificate of Ownership and registration card to and for a motor vehicle and did utter, publish, pass, and attempt to pass the same as true and genuine, to wit, Bill of Sale and vehicle registration for a 1965 Ford Cobra for
Robert O'Neil.

COUNT 11
(OFFER FALSE INSTRUMENTS)
In and between September 2000, and December 2000, at and in the County of Sacramento,
Defendant RICHARD WEAVER, did commit a felony, namely a violation of SECTION 4463(A) FIRST AMENDED COMPLAINT (FELONY) OF THE VEHICLE CODE OF THE STATE OF CALIFORNIA, in that said Defendant did unlawfully and with the intent to defraud, falsify a Certificate of Ownership and registration card to and for a motor vehicle and did utter, publish, pass, and attempt to pass the same as true and genuine, to wit, Bill of Sale and vehicle registration for a 1965 Ford Cobra for
Patrick Roth.

COUNT 12
(OFFER FALSE INSTRUMENTS)
In and between May 1, 2001, and July 12, 2001, at and in the County of Sacramento, Defendant RICHARD WEAVER, did commit a felony, namely a violation of SECTION 4463(A) OF THE VEHICLE CODE OF THE STATE OF CALIFORNIA, in that said Defendant did unlawfully and with the intent to defraud, falsify a Certificate of Ownership and registration card to and for a motor vehicle and did utter, publish, pass, and attempt to pass the same as true and genuine, to wit, Bill of Sale and vehicle registration for a 1965 Ford Cobra for
Joseph Kennedy.

COUNT 13
(OFFER FALSE INSTRUMENTS)
In and between August 1, 2000, and August 7, 2000, at and in the County of Sacramento, Defendant RICHARD WEAVER, did commit a felony, namely a violation of SECTION 4463(A) OF THE VEHICLE CODE OF THE STATE OF CALIFORNIA, in that said Defendant did unlawfully and with the intent to defraud, falsify a Certificate of Ownership and registration card to and for a motor vehicle and did utter, publish, pass, and attempt to pass the same as true and genuine, to wit, Bill of Sale and vehicle registration for a 1965 Ford Cobra for
Brian Cano.

COUNT 14
(OFFER FALSE INSTRUMENTS)
In and between December 1, 2000, and December 16, 2000, at and in the County of Sacramento, Defendant RICHARD WEAVER, did commit a felony, namely a violation of SECTION 4463(A) OF THE VEHICLE CODE OF THE STATE OF CALIFORNIA, in that said Defendant did unlawfully and with the intent to defraud, falsify a Certificate of Ownership and registration card to and for a motor vehicle and did utter, publish, pass, and attempt to pass the same as true and genuine, to wit, Bill of Sale and vehicle registration for a 1965 Ford Cobra for
John MacPherson.

COUNT 15
(OFFER FALSE INSTRUMENTS)
In and between September 1, 2000, and September 20, 2000, at and in the County of Sacramento, Defendant RICHARD WEAVER, did commit a felony, namely a violation of SECTION 4463(A) OF THE VEHICLE CODE OF THE STATE OF CALIFORNIA, in that said Defendant did unlawfully and with the intent to defraud, falsify a Certificate of Ownership and registration card to and for a motor vehicle and did utter, publish, pass, and attempt to pass the same as true and genuine, to wit, Bill of Sale and vehicle registration for a 1965 Ford Cobra for
Nathan Chesmore.

COUNT 16
(OFFER FALSE INSTRUMENTS)
In and between February 1, 2001, and May 18, 2002, at and in the County of Sacramento, Defendant RICHARD WEAVER, did commit a felony, namely a violation of SECTION 4463(A) OF THE VEHICLE CODE OF THE STATE OF CALIFORNIA, in that said Defendant did unlawfully and with the intent to defraud, falsify a Certificate of Ownership and registration card to and for a motor vehicle and did utter, publish, pass, and attempt to pass the same as true and genuine, to wit, Bill of Sale and vehicle registration for a 1966 Ford Cobra for
Michael Fagan.

COUNT 17
(OFFER FALSE INSTRUMENTS)
In and between January 1, 2001, and March 18, 2001, at and in the County of Sacramento, Defendant RICHARD WEAVER, did commit a felony, namely a violation of SECTION 4463(A) OF THE VEHICLE CODE OF THE STATE OF CALIFORNIA, in that said Defendant did unlawfully and with the intent to defraud, falsify a Certificate of Ownership and registration card to and for a motor vehicle and did utter, publish, pass, and attempt to pass the same as true and genuine, to wit, Bill of Sale and vehicle registration for a 1965 Ford Cobra for
Edward Lau.

COUNT 18
(OFFER FALSE INSTRUMENTS)
In and between November 1, 2000, and December 31, 2000, at and in the County of Sacramento, Defendant RICHARD WEAVER, did commit a felony, namely a violation of SECTION 4463(A) OF THE VEHICLE CODE OF THE STATE OF CALIFORNIA, in that said Defendant did unlawfully and with the intent to defraud, falsify a Certificate of Ownership and registration card to and for a motor vehicle and did utter, publish, pass, and attempt to pass the same as true and genuine, to wit, Bill of Sale and vehicle registration for a 1965 Ford Cobra for
Terry Brown.

TOLLING OF STATUTE LIMITATIONS
It is further alleged as to Defendant RICHARD WEAVERthat the statute of limitations has been extended pursuant to PENAL CODE SECTION 801.5 in that the above violations were continuous and that the earliest completion date of any act of the charged offenses was July 16, 2001. Pursuant to PENAL CODE SECTION 1054.5(B), the People are hereby informally requesting that defense counsel provide discovery to the People as required by PENAL CODE SECTION 1054.3, and pursuant to the provisions of PENAL CODE SECTION 1054.7. I declare upon information and belief and under penalty of perjury that the foregoing is true and correct.

Executed at Sacramento County, California, the __ day of June, 2003.
Respectfully submitted,
BILL LOCKYER
Attorney General of the State of California
ROBERT R. ANDERSON
Chief Assistant Attorney General
MARK O. GEIGER
Senior Assistant Attorney General
ROBERT M. MORGESTER
Deputy Attorney General
Attorneys for Plaintiff