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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
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