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INDSTEVEN B. WOLFSONClark County District AttorneyNevada Bar #001565BINU G. PALALChief Deputy District AttorneyNevada Bar #010178 MICHAEL R. DICKERSONDeputy District AttorneyNevada Bar #013476 200 Lewis AvenueLas Vegas, Nevada 89155-2212(702) 671-2500Attorney for PlaintiffDISTRICT COURTCLARK COUNTY, NEVADATHE STATE OF NEVADA,Plaintiff,-vs-CHRISTOPHER GENE ASHOFF#1599927,DEVIN CAMPBELL #5996722,ANTHONY WILLIAMS #1994668, TARIK GOICECHEA # 1913261ZACKARIA LUZ #1871019,RICHARD MANNING #6019091ERIC RASMUSSEN #1598211GARY KINGSLAND #1962637THOMAS RINEHART #1904415,MICHAEL CAIFANO #5347898KOREY HOOPER #1512272PETER VONDENEEN #2777211ROBERT STANDRIDGE #1905141TARA MORRIS #2650480DOROTHY MITCHELL #1242065NORMA SNYDER #1031158JESS GUTH #1680495MICHAEL SULLIVAN #1193833KEVIN STUBBS #1992318TODD BREWSTER #1630268STEPHEN GILES #2776636KODY WALKER #3018882GARY ELMORE #777386 Defendant(s).CASE NO:DEPT NO:SUPERSEDINGI N D I C T M E N TSTATE OF NEVADA)) ss.COUNTY OF CLARK)The Defendant(s) above named, CHRISTOPHER GENE ASHOFF, DEVIN CAMPBELL, ANTHONY WILLIAMS, TARIK GOICECHEA, ZACKARIA LUZ, RICHARD MANNING, ERIC RASMUSSEN, GARY KINGSLAND, THOMAS RINEHART, MICHAEL CAIFANO, KOREY HOOPER, PETER VONDENEEN, ROBERT STANDRIDGE, TARA MORRIS, DOROTHY MITCHELL, NORMA SNYDER, JESS GUTH, MICHAEL SULLIVAN, KEVIN STUBBS, TODD BREWSTER, STEPHEN GILES, KODY WALKER, and GARY ELMORE accused by the Clark County Grand Jury of the crime(s) of MURDER WITH USE OF A DEADLY WEAPON (Category A Felony - NRS 200.010, 200.030.1, 193.165 - NOC 50006); ROBBERY WITH USE OF A DEADLY WEAPON (Category B Felony – NRS 200.380, 193.165 – NOC 50138); CONSPIRACY TO COMMIT MURDER (Category B Felony - NRS 200.010, 200.030, 199.480 - NOC 50038); ATTEMPT MURDER (Category B Felony - NRS 200.010, 200.030, 193.330 - NOC 50029); TRAFFICKING IN CONTROLLED SUBSTANCE (Category A Felony - NRS 453.3385.3 - NOC 51160); SALE OF A CONTROLLED SUBSTANCE (Category B Felony – NRS 453.321.2g – NOC 51090); OWNERSHIP OR POSSESSION OF FIREARM BY PROHIBITED PERSON (Category B Felony - NRS 202.360 - NOC 51460); ASSAULT WITH A DEADLY WEAPON (Category B Felony - NRS 200.471 - NOC 50201); FORGERY OF CREDIT OR DEBIT CARD (Category D Felony – NRS 205.110 – NOC 50462); POSSESSION OF DOCUMENT OR PERSONAL INDENTIFYING INFORMATION (Category C Felony – NRS 205.465.2b – NOC 50696); ESTABLISHING OR POSSESSING A FINANCIAL FORGERY LABORATORY (Category B Felony - NRS 205.46513 - NOC 50724); UNLAWFUL POSSESSION OF SCANNING DEVICE OR REENCODER (Category C Felony – NRS 205.606 – NOC 50783); POSSESSION OF FORGED INSTRUMENT OR BILL (Category C Felony – NRS 205.160 – NOC 50469); and RACKETEERING (Category B Felony – NRS 207.350, 207.360, 207.370, 207.380, 207.390, 207.400) committed at and within the County of Clark, State of Nevada, on January 1, 2016 through August 15, 2019, as follows: COUNT 1 - MURDER WITH USE OF A DEADLY WEAPON Defendants CHRISTOPHER ASHOFF and DEVIN CAMPBELL on or about January 22, 2019, did willfully, unlawfully, feloniously and with malice aforethought, kill JOSUE CONTRERAS-VERDIN, a human being, with use of a deadly weapon, to wit: firearm, by Defendant shooting into the body of the said JOSUE CONTRERAS-VERDIN, the said killing having been willful, deliberate and premeditated; the Defendant(s) being criminally liable under one or more of the following principles of criminal liability, to wit: (1) by directly committing this crime; and/or (2) by aiding or abetting in the commission of this crime, with the intent that this crime be committed, by counseling, encouraging, hiring, commanding, inducing and/or otherwise procuring the other to commit the crime; and/or (3) pursuant to a conspiracy to commit this crime, with the intent that this crime be committed, Defendants aiding or abetting and/or conspiring by Defendants acting in concert throughout; and/or (4) in perpretation of attempted perpetration of a robbery. COUNT 2 - MURDER WITH USE OF A DEADLY WEAPON Defendants CHRISTOPHER ASHOFF and DEVIN CAMPBELL on or about January 22, 2019, did willfully, unlawfully, feloniously and with malice aforethought, kill DAVID ESPARZA-SANCHEZ aka, Juan Gonzalez-Cruz, a human being, with use of a deadly weapon, to wit: firearm, by Defendant shooting into the body of the said DAVID ESPARZA-SANCHEZ aka, Juan Gonzalez-Cruz, the said killing having been willful, deliberate and premeditated the Defendant(s) being criminally liable under one or more of the following principles of criminal liability, to wit: (1) by directly committing this crime; and/or (2) by aiding or abetting in the commission of this crime, with the intent that this crime be committed, by counseling, encouraging, hiring, commanding, inducing and/or otherwise procuring the other to commit the crime; and/or (3) pursuant to a conspiracy to commit this crime, with the intent that this crime be committed, Defendants aiding or abetting and/or conspiring by Defendants acting in concert throughout. COUNT 3 - ROBBERY WITH USE OF A DEADLY WEAPON Defendants CHRISTOPHER ASHOFF and DEVIN CAMPBELL on or about January 22, 2019, did willfully, unlawfully, and feloniously take personal property, to wit: vehicle, from the person of JOSUE CONTRERAS-VERDIN, or in his presence, by means of force or violence, or fear of injury to, and without the consent and against the will of JOSUE CONTRERAS-VERDIN, with use of a deadly weapon, to wit: a firearm, Defendant using force or fear to obtain or retain possession of the property, to prevent or overcome resistance to the taking of the property, and/or to facilitate escape; the Defendant(s) being criminally liable under one or more of the following principles of criminal liability, to wit: (1) by directly committing this crime; and/or (2) by aiding or abetting in the commission of this crime, with the intent that this crime be committed, by counseling, encouraging, hiring, commanding, inducing and/or otherwise procuring the other to commit the crime; and/or (3) pursuant to a conspiracy to commit this crime, with the intent that this crime be committed, Defendants aiding or abetting and/or conspiring by Defendants acting in concert throughout. COUNT 4 - MURDER WITH USE OF A DEADLY WEAPON Defendant DEVIN CAMPBELL did willfully, unlawfully, feloniously and with malice aforethought, kill THOMAS GLENN a human being, with use of a deadly weapon, to wit: a sharp object, by Defendant stabbing the body of the said THOMAS GLENN, the said killing having been willful, deliberate and premeditated the Defendant being criminally liable under one or more of the following principles of criminal liability, to wit: (1) by directly committing this crime; and/or (2) by aiding or abetting in the commission of this crime, with the intent that this crime be committed, by counseling, encouraging, hiring, commanding, inducing and/or otherwise procuring the other to commit the crime; and/or (3) pursuant to a conspiracy to commit this crime, with the intent that this crime be committed, Defendant aiding or abetting and/or conspiring with unknown co-conspirators acting in concert throughout. COUNT 5 - CONSPIRACY TO COMMIT MURDERDefendants ANTHONY WILLIAMS and TARIK GOICOECHEA on or about February 2, 2016, did willfully, unlawfully, and feloniously conspire with each other to commit murder, by the Defendants committing the acts as set forth in Count 3, said acts being incorporated by this reference as though fully set forth herein.COUNT 6 - MURDER WITH USE OF A DEADLY WEAPON Defendants ANTHONY WILLIAMS and TARIK GOICOECHEA, on or about February 2, 2016, did willfully, unlawfully, feloniously and with malice aforethought or in the course of a kidnapping, kill ANDREW THURGOOD, a human being, with use of a deadly weapon, to wit: a sharp object, by multiple stabbings into the body of the said ANDREW THURGOOD, the said killing having been willful, deliberate and premeditated or through the course of a kidnapping 1) by directly committing this crime; and/or (2) by aiding or abetting in the commission of this crime, with the intent that this crime be committed, by counseling, encouraging, hiring, commanding, inducing and/or otherwise procuring the other to commit the crime; and/or (3) pursuant to a conspiracy to commit this crime, with the intent that this crime be committed, Defendants aiding or abetting and/or conspiring with each other. COUNT 7 – CONSPIRACY TO COMMIT MURDERDefendants ZACKARIA LUZ, RICHARD MANNING, ERIC RASMUSSEN, and GARY KINGLSAND, on or about March 26, 2019, did willfully, unlawfully, and feloniously conspire to commit the murder of FRANCIS JENNINGS with the intent to murder FRANCIS JENNINGS.COUNT 8 – CONSPIRACY TO COMMIT MURDERDefendants ZACKARIA LUZ, RICHARD MANNING, ERIC RASMUSSEN, GARY KINGSLAND, THOMAS RINEHART, MICHAEL CAIFANO, and KOREY HOOPER, on or about April 2, 2019, did willfully, unlawfully, and feloniously conspire to commit the murder of JOHN TURNER with the intent to murder JOHN TURNER.COUNT 9 - ATTEMPT MURDER Defendants ZACKARIA LUZ, RICHARD MANNING, ERIC RASMUSSEN, GARY KINGSLAND, THOMAS RINEHART, MICHAEL CAIFANO, and KOREY HOOPER, on or about April 2, 2019, did willfully, unlawfully, feloniously and with malice aforethought attempt to kill JOHN TURNER, a human being, 1) by directly committing this crime; and/or (2) by aiding or abetting in the commission of this crime, with the intent that this crime be committed, by counseling, encouraging, hiring, commanding, inducing and/or otherwise procuring the other to commit the crime; and/or (3) pursuant to a conspiracy to commit this crime, with the intent that this crime be committed, Defendants aiding or abetting and/or conspiring with each other and/or an unknown co-conspirator, Defendants and/or unnamed co-conspirator acting in concert throughout.COUNT 10 - ACCESSORY TO ((FELONY CHARGE))Defendant PETER VONDENEEN did on or about April 2, 2019, willfully, unlawfully, and feloniously, after the commission of a Attempt Murder, a felony, harbor and/or conceal GARY KINGSLAND, THOMAS RINEHART and MICHAEL CAIFANO, with the intent that GARY KINGSLAND, THOMAS RINEHART and MICHAEL CAIFANO might avoid or escape arrest, trial, conviction, and/or punishment, having knowledge that GARY KINGSLAND, THOMAS RINEHART and MICHAEL CAIFANO had committed Attempt Murder and/or was liable to arrest therefore.COUNT 11 – CONSPIRACY TO COMMIT MURDERDefendants ZACKARIA LUZ, RICHARD MANNING, GARY KINGSLAND, THOMAS RINEHART, MICHAEL CAIFANO, ROBERT STANDRIDGE and TARA MORRIS, on or about April 15, 2019, did willfully, unlawfully, and feloniously conspire to commit the murder of JENNA CRANK with the intent to murder JENNA CRANK.COUNT 12 - ROBBERY WITH USE OF A DEADLY WEAPON Defendant KODY WALKER, on or about January 10, 2019, did willfully, unlawfully, and feloniously take personal property, to wit: a backpack and contents, from the person of JAMES DURBIN, or in his presence, by means of force or violence, or fear of injury to, and without the consent and against the will of JAMES DURBIN, with use of a deadly weapon, to wit: a knife, Defendant using force or fear to obtain or retain possession of the property, to prevent or overcome resistance to the taking of the property, and/or to facilitate escape.COUNT 13 - BURGLARY Defendant KODY WALKER, on or about January 10, 2019, did willfully, unlawfully, and feloniously enter a 2008 Nissan, bearing Nevada License No. UNLV16052, owned or occupied by JAMES DURBIN, located at 2450 East Pebble Road, Las Vegas, Clark County, Nevada, with intent to commit larceny.COUNT 14 - TRAFFICKING IN CONTROLLED SUBSTANCE Defendant DOROTHY MITCHELL did on or about January 17, 2019, willfully, unlawfully, feloniously, and knowingly or intentionally possess, either actually or constructively, 28 grams or more, to wit: approximately 65 grams of Methamphetamine, or any mixture of substance consisting of approximately 65 grams containing the controlled substance Methamphetamine.COUNT 15 - TRAFFICKING IN CONTROLLED SUBSTANCEDefendant MICHAEL SULLIVAN, did, on or about February 27, 2019, willfully, unlawfully, feloniously, and knowingly or intentionally possess, either actually or constructively, 28 grams or more, to wit: approximately 145 grams of Methamphetamine, or any mixture of substance consisting of approximately 145 grams containing the controlled substance Methamphetamine.COUNT 16 - SALE OF CONTROLLED SUBSTANCE Defendant MICHAEL SULLIVAN did on or about February 27, 2019, willfully, unlawfully, and feloniously sell to T.M., a controlled substance, to wit: Methamphetamine. COUNT 17 - OWNERSHIP OR POSSESSION OF FIREARM BY PROHIBITED PERSONDefendant MICHAEL SULLIVAN did, on or about March 6, 2019, willfully, unlawfully, and feloniously own, or have in his possession and/or under his custody or control, a firearm, to wit: a Smith and Westin semi-automatic pistol, the Defendant being a convicted felon, having in 2006, been convicted of Attempt Possession of Controlled Substance, in Case No. C212257, in the Eighth Judicial District Court, Clark County, a felony under the laws of the State of Nevada.COUNT 18 - OWNERSHIP OR POSSESSION OF FIREARM BY PROHIBITED PERSONDefendant MICHAEL SULLIVAN did, on or about March 6, 2019, willfully, unlawfully, and feloniously own, or have in his possession and/or under his custody or control, a firearm, to wit: a Magnum pump action shotgun, the Defendant being a convicted felon, having in 2006, been convicted of Attempt Possession of Controlled Substance, in Case No. C212257, in the Eighth Judicial District Court, Clark County, a felony under the laws of the State of Nevada.COUNT 19 - TRAFFICKING IN CONTROLLED SUBSTANCEDefendants NORMA SNYDER and JESS GUTH, did, on or about March 11, 2019, willfully, unlawfully, feloniously, and knowingly or intentionally possess, either actually or constructively, 28 grams or more, to wit: approximately 256 grams of Methamphetamine, or any mixture of substance consisting of approximately 256 grams containing the controlled substance Methamphetamine.COUNT 20 - SALE OF CONTROLLED SUBSTANCE Defendants NORMA SNYDER and JESS GUTH did on or about March 11, 2019, willfully, unlawfully, and feloniously sell to T.M., a controlled substance, to wit: Methamphetamine 1) by directly committing this crime; and/or (2) by aiding or abetting in the commission of this crime, with the intent that this crime be committed, by counseling, encouraging, hiring, commanding, inducing and/or otherwise procuring the other to commit the crime; and/or (3) pursuant to a conspiracy to commit this crime, with the intent that this crime be committed, Defendants aiding or abetting and/or conspiring with each other and/or an unknown co-conspirator, Defendants and/or unnamed co-conspirator acting in concert throughout.COUNT 21 - TRAFFICKING IN CONTROLLED SUBSTANCEDefendants NORMA SNYDER and JESS GUTH, did, on or about March 21, 2019, willfully, unlawfully, feloniously, and knowingly or intentionally possess, either actually or constructively, 28 grams or more, to wit: approximately 260 grams of Methamphetamine, or any mixture of substance consisting of approximately 260 grams containing the controlled substance Methamphetamine.COUNT 22 - SALE OF CONTROLLED SUBSTANCE Defendants NORMA SNYDER and JESS GUTH did on or about March 21, 2019, willfully, unlawfully, and feloniously sell to T.M., a controlled substance, to wit: Methamphetamine 1) by directly committing this crime; and/or (2) by aiding or abetting in the commission of this crime, with the intent that this crime be committed, by counseling, encouraging, hiring, commanding, inducing and/or otherwise procuring the other to commit the crime; and/or (3) pursuant to a conspiracy to commit this crime, with the intent that this crime be committed, Defendants aiding or abetting and/or conspiring with each other and/or an unknown co-conspirator, Defendants and/or unnamed co-conspirator acting in concert throughout.COUNT 23 - TRAFFICKING IN CONTROLLED SUBSTANCEDefendants NORMA SNYDER and JESS GUTH, did, on or about March 21, 2019, willfully, unlawfully, feloniously, and knowingly or intentionally possess, either actually or constructively, 28 grams or more, to wit: approximately 260 grams of Methamphetamine, or any mixture of substance consisting of approximately 260 grams containing the controlled substance Methamphetamine.COUNT 24 - TRAFFICKING IN CONTROLLED SUBSTANCEDefendants NORMA SNYDER and JESS GUTH, did, on or about March 27, 2019, willfully, unlawfully, feloniously, and knowingly or intentionally possess, either actually or constructively, 28 grams or more, to wit: approximately 260 grams of Methamphetamine, or any mixture of substance consisting of approximately 260 grams containing the controlled substance Methamphetamine.COUNT 25 - ASSAULT WITH A DEADLY WEAPON Defendant KEVIN STUBBS did on or about March 28, 2019, willfully, unlawfully, feloniously and intentionally place another person in reasonable apprehension of immediate bodily harm and/or did willfully and unlawfully attempt to use physical force against another person, to wit: KEALOHA LLEWELLYN, with use of a deadly weapon, to wit: a firearm, by pointing said firearm at KEALOHA LLEWELLYN and threatening to shoot him.COUNT 26 - CARRYING CONCEALED FIREARM OR OTHER DEADLY WEAPONDefendant KEVIN STUBBS did on or about March 28, 2019, then and there willfully, unlawfully and feloniously carry concealed upon his person, a firearm or other deadly weapon, to wit: firearm.COUNT 27 - TRAFFICKING IN CONTROLLED SUBSTANCE Defendant KEVIN STUBBS did on or about April 9, 2019, willfully, unlawfully, feloniously, and knowingly or intentionally possess, either actually or constructively, 28 grams or more, to wit: approximately 46.6 grams of Cocaine, or any mixture of substance consisting of approximately 46.6 grams containing the controlled substance Cocaine.COUNT 28 - TRAFFICKING IN CONTROLLED SUBSTANCEDefendant KEVIN STUBBS did on or about April 9, 2019, willfully, unlawfully, feloniously, and knowingly or intentionally possess, either actually or constructively, 4 grams or more, but less than 14 grams, to wit: approximately 12.4 grams of Methamphetamine, or any mixture of substance consisting of approximately 12.4 grams containing the controlled substance Methamphetamine.COUNT 29 - FORGERY OF CREDIT OR DEBIT CARDDefendant KEVIN STUBBS did on or about April 9, 2019, willfully, unlawfully and feloniously, with intent to defraud, possess, with intent to utter, offer, dispose of or to put off a forged credit or debit card, to wit: a purported Wells Fargo credit card account ending in 6046, knowing the same to be forged or altered.COUNT 30 - FORGERY OF CREDIT OR DEBIT CARDDefendant KEVIN STUBBS did on or about April 9, 2019, willfully, unlawfully and feloniously, with intent to defraud, possess, with intent to utter, offer, dispose of or to put off a forged credit or debit card, to wit: a purported Care Credit MasterCard account ending in 9227, knowing the same to be forged or altered.COUNT 31 - FORGERY OF CREDIT OR DEBIT CARDDefendant KEVIN STUBBS did on or about April 9, 2019, willfully, unlawfully and feloniously, with intent to defraud, possess, with intent to utter, offer, dispose of or to put off a forged credit or debit card, to wit: a purported First National Bank card account ending in 0606, knowing the same to be forged or altered.COUNT 32 - FORGERY OF CREDIT OR DEBIT CARDDefendant KEVIN STUBBS did on or about April 9, 2019, did then and there willfully, unlawfully and feloniously, with intent to defraud, possess, with intent to utter, offer, dispose of or to put off a forged credit or debit card, to wit: a purported U.S. Bank Visa card account ending in 8627, knowing the same to be forged or altered.COUNT 33 - FORGERY OF CREDIT OR DEBIT CARDDefendant KEVIN STUBBS did on or about April 9, 2019, did then and there willfully, unlawfully and feloniously, with intent to defraud, possess, with intent to utter, offer, dispose of or to put off a forged credit or debit card, to wit: a purported U.S. Bank Visa card account ending in 2451, knowing the same to be forged or altered.COUNT 34 - FORGERY OF CREDIT OR DEBIT CARDDefendant KEVIN STUBBS did on or about April 9, 2019, did then and there willfully, unlawfully and feloniously, with intent to defraud, possess, with intent to utter, offer, dispose of or to put off a forged credit or debit card, to wit: a purported Navy Federal Credit Union card account ending in 8514, knowing the same to be forged or altered.COUNT 35 - FORGERY OF CREDIT OR DEBIT CARDDefendant KEVIN STUBBS did on or about April 9, 2019, did then and there willfully, unlawfully and feloniously, with intent to defraud, possess, with intent to utter, offer, dispose of or to put off a forged credit or debit card, to wit: a purported CitiBank MasterCard account ending in 9363, knowing the same to be forged or altered.COUNT 36 - FORGERY OF CREDIT OR DEBIT CARDDefendant KEVIN STUBBS did on or about April 9, 2019, did then and there willfully, unlawfully and feloniously, with intent to defraud, possess, with intent to utter, offer, dispose of or to put off a forged credit or debit card, to wit: a purported Chase Visa card account ending in 3536, knowing the same to be forged or altered.COUNT 37 - FORGERY OF CREDIT OR DEBIT CARDDefendant KEVIN STUBBS did on or about April 9, 2019, willfully, unlawfully and feloniously, with intent to defraud, possess, with intent to utter, offer, dispose of or to put off a forged credit or debit card, to wit: a purported CitiBank MasterCard account ending in 2742, knowing the same to be forged or altered.COUNT 38 - FORGERY OF CREDIT OR DEBIT CARDDefendant KEVIN STUBBS did on or about April 9, 2019, willfully, unlawfully and feloniously, with intent to defraud, possess, with intent to utter, offer, dispose of or to put off a forged credit or debit card, to wit: a purported CitiBank Visa card account ending in 1698, knowing the same to be forged or altered.COUNT 39 - FORGERY OF CREDIT OR DEBIT CARDDefendant KEVIN STUBBS did on or about April 9, 2019, willfully, unlawfully and feloniously, with intent to defraud, possess, with intent to utter, offer, dispose of or to put off a forged credit or debit card, to wit: a purported Navy Federal Credit Union Visa card account ending in 4722, knowing the same to be forged or altered.COUNT 40 - FORGERY OF CREDIT OR DEBIT CARDDefendant KEVIN STUBBS did on or about April 9, 2019, willfully, unlawfully and feloniously, with intent to defraud, possess, with intent to utter, offer, dispose of or to put off a forged credit or debit card, to wit: a purported Wells Fargo Visa card account ending in 5758, knowing the same to be forged or altered.COUNT 41 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATIONDefendant KEVIN STUBBS did on or about April 9, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: a purported Florida driver's license bearing the name SETH CALLEY, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 42 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATIONDefendant KEVIN STUBBS did on or about April 9, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: a purported Nevada driver's license bearing the name ALAN PAGANELLI, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 43 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATIONDefendant KEVIN STUBBS did on or about April 9, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: a purported Nevada driver's license bearing the name KRISTOFFER ROSANO, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 44 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATIONDefendant KEVIN STUBBS did on or about April 9, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: a purported Nevada driver's license bearing the name CYNTHIA RECINOS, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 45 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATIONDefendant KEVIN STUBBS did on or about April 9, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: a purported Nevada driver's license bearing the name JULIUS SPENCE, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 46 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATIONDefendant KEVIN STUBBS did on or about April 9, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: a purported Nevada driver's license bearing the name MISCHAEL FISCUS, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 47 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATIONDefendant KEVIN STUBBS did on or about April 9, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: a purported California driver's license bearing the name LESTER LIM, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 48 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATIONDefendant KEVIN STUBBS did on or about April 9, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: a purported Nevada driver's license bearing the name ERIKA ROBLES, for the purpose of establishing a false status, occupation, membership, license or identity for herself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 49 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATIONDefendant KEVIN STUBBS did on or about April 9, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: a purported Nevada driver's license bearing the name PAMELA LAAS, for the purpose of establishing a false status, occupation, membership, license or identity for herself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 50 - ESTABLISHING OR POSSESSING A FINANCIAL FORGERY LABORATORY Defendant KEVIN STUBBS did on or about April 9, 2019, willfully, knowingly and feloniously establish or possess a financial forgery laboratory, to wit: laptops, Dremel tool, card stock, check stock, scanner, embosser and/or card readers, with the intent to commit any unlawful act. COUNT 51 - UNLAWFUL POSSESSION OF SCANNING DEVICE OR REENCODERDefendant ZACHARIA LUZ did on or about April 26, 2019, willfully, unlawfully and feloniously possess a scanning device or reencoder with the intent to use the scanning device or reencoder for an unlawful purpose.COUNT 52 - UNLAWFUL POSSESSION OF SCANNING DEVICE OR REENCODERDefendant ZACHARIA LUZ did on or about April 26, 2019, willfully, unlawfully and feloniously possess a scanning device or reencoder with the intent to use the scanning device or reencoder for an unlawful purpose.COUNT 53 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of MARIO HERNANDEZ RAMIREZ, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 54 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATIONDefendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of MATTHEW PATTON, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 55 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of JEREMY HESTER, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 56 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of CYNTHIA JANISH, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 57 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of LESLIE SMITH, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 58 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATIONDefendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of ERIC PARKER, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 59 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATIONDefendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of ANJALEEK REYES, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 60 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of LAURA MONROY GRAVES, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 61 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name and address of LETICIA JOHNSON, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 62 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth, address and Social Security Number of MARY DUNN, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 63 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of FAEGHEH AGHARMIRI, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 64 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of EDALYNN TOY, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 65 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATIONDefendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of WILLIAM SHAY, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 66 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of PETER FINK, JR., for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 67 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of CARL ROBERTSON, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 68 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name and date of birth of JUNGYI CHEN, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 69 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATIONDefendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of ADOLFO PINON VALEZ, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 70 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of PERLA PINON, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 71 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of MARIE MCCAW, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 72 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of CARL GILKERSON, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 73 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of YANET RUIS DIAZ, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 74 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATIONDefendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and name of ERIC FISHER, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 75 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of CHADLEE NORRIS, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 76 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of STEPHANIE BEAN, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 77 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of CURTI NEWMAN, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 78 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of RICHARD BLACK, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 79 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of TIMOTHY HUSTED, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 80 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of LORI SHARP, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 81 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of ANY COFFMAN, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 82 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATIONDefendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of QUANNA CRAFT, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 83 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of NATHAN PARKER, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 84 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name and Social Security Number of NANCY CRUZ, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 85 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name and Social Security Number of MICHAEL FIELDS, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 86 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name and Social Security Number of PENELOPE HUFFINES, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 87 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name and Social Security Number of JONATHAN WILLIAMS, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 88 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name and date of birth of RACHEL TABER, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 89 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name and date of birth of MALCOLM KEMP, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 90 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name and date of birth of KELLY HOLM KEMP, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 91 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name and Social Security number of KELLY ANN HOLM, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 92 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name and Social Security Number of WILLIAM SHAY, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 93 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name and Social Security Number of CARTER SING, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 94 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATIONDefendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name and Social Security Number of KENNETH HUFFINES, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 95 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name and Social Security Number of ANTWAN WILLIAMS, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 96 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATIONDefendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name and Social Security Number of DOUGLAS FENSTER, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 97 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name and Social Security Number of CYTHIA JANISH, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 98 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name and Social Security Number of MICHALE FIELDS, JR., for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 99 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name and Social Security Number of ANDREW RIZK, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 100 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, Social Security Number and address of JERAMIE WUP, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 101 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, Social Security Number and address of NATHAN KANAE, SR., for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 102 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, Social Security Number and address of JENNY LI, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 103 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, Social Security Number and address of WANG FU WANG, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 104 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth, Social Security Number and address of MICAHEL WAS, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 105 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth, Social Security Number and address of AARON CALE, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 106 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, Social Security Number and address of JACKSON CALE, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 107 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name and address of JUANA-HART AKERS, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 108 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, Social Security Number and address of TROY FULLERTON, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 109 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth, Social Security Number and address of ELUZAL REYES, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 110 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, Social Security Number and address of ELUZAL REYES, JR., for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 111 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of JOSHUA BYERS, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 112 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, Social Security Number and address of DUSTIN HIGH, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 113 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, Social Security Number and address of LOUIS BUSH, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 114 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name KELLY KEMP, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 115 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth, Social Security Number and address of LUCY GREEN, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 116 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of MADELINE GALLO CASTILLO, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 117 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth, Social Security Number and address of LYLON RICHARDS, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 118 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth an address of WENDELL GILKEY, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 119 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of KENNETH CLARK, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 120 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name and Social Security Number of LEE ALEX WASSERMAN, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 121 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name and address of ALEXANDER MIRELES, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 122 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, Social Security Number and address of LUCILLA VARELA, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 123 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, Social Security Number and address of LUCILA VARELA, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 124 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, Social Security Number and address of ROBERTO VARELA, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 125 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, Social Security Number and addres of VIVIAN VARELA, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 126 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth, Social Security Number and addres of JOSHUA AMANDO, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 127 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth, Social Security number and address of ROBERTA GRIPPO, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 128 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth and address of NATALIA RODRIGUEZ, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 129 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name and Social Security Number of KRIS BIRCH, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 130 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth, Social Security Number and address of KHRISTIAN GARCIA, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 131 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth, Social Security Number and address of JOSEPH GARCIA, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 132 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth, Social Security Number and address of ISSABELLE HILDEBRAND, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 133 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth, Social Security Number and address of KELCEE HILDEBRAND, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 134 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant ZACHARIA LUZ did on or about April 26, 2019, did willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: the name, date of birth, Social Security Number and address of JOSEPHINE GARCIA, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 135 - ESTABLISHING OR POSSESSING A FINANCIAL FORGERY LABORATORY Defendant TODD BREWSTER did on or about May 28, 2019 willfully, knowingly and feloniously establish or possess a financial forgery laboratory, to wit: a laptop and/or a tablet and/or altered checks and/or forged currency and/or profile information and/or a check stock and/or credit cards in the name of others, with the intent to commit any unlawful act. COUNT 136 - POSSESSION OF FORGED INSTRUMENT OR BILL Defendant TODD BREWSTER did on or about May 28, 2019 willfully, unlawfully, and feloniously have in his possession, knowing it to be forged or counterfeited, a forged promissory note, traveler's check, money order, bill for the payment of money or property, and/or blank bill, to wit: one (1) counterfeit Federal Reserve Note(s) in the sum of $100.00, with the intent to pass it and/or permit, cause, or procure it to be uttered or passed, with the intent to defraud.COUNT 137 - POSSESSION OF FORGED INSTRUMENT OR BILL Defendant TODD BREWSTER did on or about May 28, 2019 willfully, unlawfully, and feloniously have in his possession, knowing it to be forged or counterfeited, a forged promissory note, traveler's check, money order, bill for the payment of money or property, and/or blank bill, to wit: seven (7) counterfeit Federal Reserve Note(s) in the sum of $50.00, with the intent to pass it and/or permit, cause, or procure it to be uttered or passed, with the intent to defraud.COUNT 138 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant TODD BREWSTER did on or about May 28, 2019 willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: a Nevada Driver's License, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 139 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant TODD BREWSTER did on or about May 28, 2019 willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: a Nevada Driver's License, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 140 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant TODD BREWSTER did on or about May 28, 2019 willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: Pennsylvania Driver’s License, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 141 - POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION Defendant TODD BREWSTER did on or about May 28, 2019 willfully, knowingly, and feloniously possess any document or personal identifying information, to wit: a Mississippi Driver’s License, for the purpose of establishing a false status, occupation, membership, license or identity for himself or any other person, to commit any of the crimes set forth in NRS 205.085 through 205.217, inclusive, 205.473 through 205.513, inclusive or 205.610 through 205.810, inclusive.COUNT 142 - POSSESSION OF CREDIT OR DEBIT CARD WITHOUT CARDHOLDER'S CONSENT Defendant TODD BREWSTER did on or about May 28, 2019 willfully, unlawfully, and feloniously, have in his possession, without the consent of the cardholder, a credit or debit card, to wit: a Visa card ending in 1195, issued in the name of MARTHA BRYAN, with intent to circulate, use, sell, or transfer said card, with intent to defraud the cardholder and/or the issuer of said credit or debit card.COUNT 143 - POSSESSION OF CREDIT OR DEBIT CARD WITHOUT CARDHOLDER'S CONSENT Defendant TODD BREWSTER did on or about May 28, 2019 willfully, unlawfully, and feloniously, have in his possession, without the consent of the cardholder, a credit or debit card, to wit: a MasterCard ending in 4576, issued in the name of MICHAEL CAFIANO, with intent to circulate, use, sell, or transfer said card, with intent to defraud the cardholder and/or the issuer of said credit or debit card.COUNT 144 - POSSESSION OF CREDIT OR DEBIT CARD WITHOUT CARDHOLDER'S CONSENT Defendant TODD BREWSTER did on or about May 28, 2019 willfully, unlawfully, and feloniously, have in his possession, without the consent of the cardholder, a credit or debit card, to wit: a MasterCard ending in 5094, issued in the name of LEAH MAGLIARI, with intent to circulate, use, sell, or transfer said card, with intent to defraud the cardholder and/or the issuer of said credit or debit card.COUNT 145 - FORGERY OF CREDIT OR DEBIT CARD Defendant TODD BREWSTER did on or about May 28, 2019 then and there willfully, unlawfully and feloniously, with intent to defraud, possess, with intent to utter, offer, dispose of or to put off a forged credit or debit card, to wit: a forged Visa card ending in 8860, knowing the same to be forged or altered.COUNT 146 - FORGERY OF CREDIT OR DEBIT CARD Defendant TODD BREWSTER did on or about May 28, 2019 then and there willfully, unlawfully and feloniously, with intent to defraud, possess, with intent to utter, offer, dispose of or to put off a forged credit or debit card, to wit: a forged MasterCard ending in 3152, knowing the same to be forged or altered.COUNT 147 - FORGERY OF CREDIT OR DEBIT CARD Defendant TODD BREWSTER did on or about May 28, 2019 then and there willfully, unlawfully and feloniously, with intent to defraud, possess, with intent to utter, offer, dispose of or to put off a forged credit or debit card, to wit: a forged Visa card ending in 0662, knowing the same to be forged or altered.COUNT 148 - FORGERY Defendant TODD BREWSTER did on or about May 28, 2019 then and there willfully, unlawfully and feloniously, knowing the same to be forged or altered, possess, with intent to utter, offer, dispose of, or to put off as true, and with the intent to defraud, a forged writing, instrument or other thing, to wit: a check in the name of Tracey Mitchusson made to a Daniel Mclaughlin, the false making, forging, or altering of which is punishable as forgery.COUNT 149 - RACKETEERINGDefendants, did on or between January 1, 2016 through August 15, 2019, within Clark County, Nevada, knowingly, willfully and feloniously, while associated with an enterprise, conduct or participate either directly or indirectly, in racketeering activity through the affairs of said enterprise, including but not limited to engaging in racketeering activity; and/or intentionally organizing, managing, directing, supervising, or financing a criminal syndicate; and/or knowingly inciting or inducing others to engage in violence or intimidation to promote or further the criminal objectives of the criminal syndicate; and/or did give advice, assistance, or direction in the conduct, financing or management of the affairs of the criminal syndicate with the intent to promote the criminal objectives of the syndicate; and/or did transport property to provide and/or attempt to provide said property to another person knowing that the other person intended to use the property to further racketeering activity; and or did conspire to engage in said acts, to wit: defendants being members or associates of the criminal syndicate the ARYAN WARRIORS, were all involved in the operations of the ARYAN WARRIORS, organized as a para-military group, through the use of violence and/or conspiring to commit violence, in order to obtain greater access to the illegal controlled substance market and/or to prevent members or others from cooperating with law enforcement, and/or through trafficking and/or selling controlled substances and/or possessing forgery laboratories, forged credit cards, forged currency in order to finance the ARYAN WARRIORS and/or a white supremacist ideology; and/or defendants organizing, managing, directing, supervising and/or financing the ARYAN WARRIORS criminal syndicate, by instructing members to commit violence on behalf of the ARYAN WARRIORS as well as to participate in illegal controlled substance trade and/or forgery schemes to fund the ARYAN WARRIORS; and/or knowingly inciting and inducing others to commit violence in order to be promoted within the ARYAN WARRIORS hierarchy and/or to punish and/or prevent witnesses from assisting law enforcement investigations into the ARYAN WARRIORS; and/or transporting illegal narcotics, forgery labs, forged credit cards, forged currency, and/or personal identifying information of others to further racketeering activity; and/or engaging racketeering activity as alleged in prior Counts and fully incorporated herein or previously being convicted of racketeering activity: Defendants being responsible under one or more of the following principles of criminal liability, to wit (1) by the defendants directly committing the crime; and/or (2) by the defendants aiding or abetting others in the commission of the crime; and/or (3) by the Defendants conspiring to commit the crime.DATED this day of DATE \@ "MMMM, yyyy" \* MERGEFORMAT August, 2019.STEVEN B. WOLFSONClark County District AttorneyNevada Bar #001565BYBINU G. PALALChief Deputy District AttorneyNevada Bar #010178 ENDORSEMENT: A True BillForeperson, Clark County Grand Jury ................
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