IND ADAM PAUL LAXALT ‘Attomey General FILED IN OPEN courT DANIEL WESTMEYER ‘STEVEN D. GRIERSON Senior Deputy Attorney General CLERK OF THE COURT ‘Nevada Bar Number 10273 CHELSEA KALLAS AUG 02 2017 Deputy Attorney General Nevada Bar Number 13902 555 E Washington Ave, Ste, 3900 Ca Las Vegas, NV 89101-1608 ‘DULCE MARIE ROMEA DEPUTY dwestmeyer@ag.nv.gov ckallas@ag.nv. pov Attorneys forthe State of Nevada DISTRICT COURT CLARK COUNTY, NEVADA. ‘THE STATE OF NEVADA, Plaintiff, Case No.: C-17-325448-3 vs Dept. No: XXV ROBERT MILK ID#1261837, KENNETH JOHNSON 1D#2584164, ‘CURTIS ACRE 1D#3029209, ROOSEVELT WARREN ID#2i22938, KRISTI MILK, and JOEL HENDRIX ID#1524787 Defendants INDICTMENT Defendans, ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, ROOSEVELT WARREN, KRISTI MILK, and JOEL HENDRIX, above named, are accused by the Grand Jury of having committed the following offenses: OFFERING FALSE INSTRUMENT FOR FILING OR RECORD, « category “C* felony in violation of NRS 239,330; OBTAINING MONEY OR PROPERTY UNDER FALSE PRETENSES, a category “B” felony in violation of NRS 205.380; MORTGAGE LENDING FRAUD, a category “C" jolation of NRS 205372; OBTAINING AND USING PERSONAL IDENTIFYING INFORMATION OF ANOTHER, a category “B” felony in violation of NRS 205.463; and BURGLARY, a category “B” felony, in violation of NRS 205.060. felony in[All ofthe acts alleged herein have been committed or consummated on or between November 12013 and February 2017, by the above-named Defendants, executed in whole or in part within th) County of Clack, State of Nevada, in the following manner: CATEGORY “C” Felony - NRS 239.330 Defendants ROBERT MILK, KENNETH JOHNSON, and CURTIS ACRE, in the County of tar, State of Nevada, either by vite of their own actions or by the actions of ther agents or employees, withoxt lawful authority, knowingly procured or offered a false instrament tobe fled, to wit (On or about August 25, 2014, Defendants ROBERT MILK, KENNETH JOHNSON, and CURTIS ACRE, without lawful authority, with the Defendants being criminally liable under one or more of the following principles of criminal liability, to-wit: (1) by directly committing ths crime; andlor (2) by aiding or abetting in the commission of this crime, withthe intent that this crime be ‘committed, by providing counsel and/or encouragement and by entering into a course of condi whereby KENNETH JOHNSON owned or operated NV Ranch dba Statewide Towing, and/r CURTS| ACRE owned o: operated Towing Jamison dba Statewide Towing; and whereby ROBERT MILK and KENNETH JOHNSON acted as agents of sid entities andor received monies from a bank seoout i the name of si entities; and whereby CURTIS ACRE offered false documents for filing; andlor) pursuant to a conspiracy to commit this crime, with the intent that the crime be commited; nowingly offered for fling with the Department of Motor Vehicles a “Lien Sale Affidavit” andlor “Lien Claimant's Certication” for a 2007 BMW, bearing VIN WBXPC934X7WJ02201, knowing ssid documents to be false, which documents if genuine might be filed with the Deparment of Mote Vehicles under te laws ofthe State of Nevada, [Al of which constitutes the rime of OFFERING FALSE INSTRUMENT FOR FILING OR RECORD, a category “felony in violation of NRS 239.330. COUNT ‘CATEGORY “C” Felony - NRS 239.330Defendants ROBERT MILK, KENNETH JOHNSON, and CURTIS ACREE, in the County of Clark, State of Nevada, either by virtue of their own actions or by the actions of their agents ot employees, without lawfil authority, knowingly procured ot offered a false instrument to be filed, to wit: 7 (On or sbout June 16, 2014, Defendants ROBERT MILK, KENNETH JOHNSON, and CURTIS} | ACRE, without lawful authority, with the Defendants being criminally liable under one or more ofthe following principles of criminal liability, to-wit: (1) by direetly committing this erime; nor 2) by| aiding or abetting in the commission of this erime, with the intent that this erime be committed, by providing counsel and/ot encouragement and by entering into a course of conduct whereby KENNETH JOHNSON owned or oferated NV Ranch dba Statewide Towing, and/or CURTIS ACRE owned of operated Towing Jamison dba Statewide Towing; and whereby ROBERT MILK and KENNETH) JOHNSON acted as agents of said entities and/or received monies from a bank account inthe name of| suid entities; and/or (3) pursuant to a conspiracy to commit this crime, with the intent thatthe crime be| commited; knowingly offered for filing with the Department of Motor Vehicles a “Lien Sale Affidavit” and/or a“Lien Claimant's Certification” for a 2013 Ford Taurus, bearing VIN IFAHP2KT3D6136396, | knowing said documents to be false, which documents if genuine might be filed withthe Department of Motor Vehicles under the laws of the State of Nevada. All of which constitutes the crime of OFFERING FALSE INSTRUMENT FOR FILING OR] RECORD, a category “C” felony in violation of NRS 239.330. COUNTS oF 7 ‘CATEGORY “C” Felony - NRS 239.330 Defendants ROBERT MILK, KENNETH JOHNSON, and ROOSEVELT WARREN, in the County of Clark, State of Nevada, either by virtue of their own actions or by the actions oftheir agent or employees, without wful authority, knowingly procured or offered a false instrument o be filed, t0 wit: ~ (On or about November 5, 2013, Defendants ROBERT MILK, KENNETH JOHNSON, and ROOSEVELT WARREN, without lawful authority, with the Defendants being criminally liable unde1 |lone or more of the following principles of criminal liability, to-wit: (1) by directly commiting this crime; and/or (2) by aiding or abetting inthe commission of this crime, withthe intent tht this crime be| committed, by providing counsel and/or encouragement and by entering into a course of conduct whereby KENNETH JOHNSON owned or operated NV Ranch Inc. and/or Aquarius Towing and/or| ]NVT Storage and ROOSFVEILT WARREN claimed to bea revstred owner; and whey ROBERT MILK and KENNETH JONSON acted as agents of said entities andor obisined monies fm a bank account in the name of sid entities; and whereby KENNETH JOHNSON offered false documents for fling; andor 3) pursuant to a conspraey to commit this crime, withthe inet thatthe cme be commited; knowingly offered for filing with the Deparment of Motor Vehicles a“Lien Sale Afi 10 [andor “Lien Claimant's Certification” for 2008 Toyota Sienna, bearing VIN 11 || stpzx22c68s13580s, knowing seid documents 10 be false, which documents if genuine might be 12 |] ed withthe Department of Motor Vehicles under he laws ofthe Sate of Nevada. B {Al of which constitutes the crne of OFFERING FALSE INSTRUMENT FOR FILING OR 14 |] RECORD, a category“ felony in violation of NRS 239.330. a Cours - ‘CATEGORY “C” Felony - NRS 239.330 18 Defendants ROBERT MILK, ROOSEVELT WARREN, and JOEL HENDRIX inthe County of| 19 || ci, State of Nevad, citer by virtue oftheir own actions or by the actions oftheir agents ot 20 | |empoyees, without ivful authority, knowingly procured or offered false instrument tobe fied, to 21 [fie 2 (nor about September 6, 2016 Defendants ROBERT MILK, ROOSEVELT WARREN, and 25 ||s081 HENDRIX, without lawl authority, withthe Defendants being criminally liable under one or 24 || more ofthe following principles of criminal liability, to-wit (1) by relly commiting hi erime; 25 ||andlor @) by siding or sbetng inthe commission ofthis crime, with the intent tht his crime be 26 |lcommited, by providing counsel andlor encouragement and by entering into a course of conduct 27 || whereby ROBERT MILK, ROOSEVELT WARREN, and JOEL HENDRIX operated Tow Guys, Inc. 2g || andlor KBR Auto; and whereby ROBERT MILK, ROOSEVELT WARREN, and JOEL HENDRIX|2 4 25 the name of sai ent acted as agents of said entities and/or obtained monies from a bank account and whereby ROBERT MILK, ROOSEVELT WARREN, and/or JOEL HENDRIX falsely appended Westside Auto & Storage” and/or “David Smith” andlor “Tow Guys" to lien sale documents; and/or (3) pursuant 10 & conspiracy to commit this crime, with the intent that the crime be commited owing! offered fr fing with the Department of Motor Vehicles a “Lien Sle Avi” andor a Lien Chiman’s Cenifcation” for a 2014 BMW 7501, bearing VIN WBAYAGCSOEDS!5400,| knowing id document tobe false, which documents if genuine might be filed with he Department of] Motor Vehicles under he laws ofthe State of Nevada [Alf which consis the rime of OFFERING FALSE INSTRUMENT FOR FILING OR RECORD, a category “C" felony in violation of NRS 239.330. COUNTS ‘CATEGORY “C” Felony - NRS 239.330 Defendants ROBERT MILK, ROOSEVELT WARREN, and JOEL HENDRIX inthe County of| Clark, State of Nevada, either by virtue of their own actions or by the actions of their agents or employees, without lawful authority, knowingly procured or offered a false instrument to be filed, to wit Cn or about February 1, 2017, Defendants ROBERT MILK, ROOSEVELT WARREN, and| JOEL HENDRIX without lawful authority, with the Defendants being criminally liable under one oF more ofthe following principles of criminal liability, to-wit: (1) by directly commiting this crime; and/or (2) by aiding or abetting in the commission of this crime, with the intent that this crime be| commitsd, by providing counsel and/or encouragement and hy entering into a coune of conduct whereby ROBERT MILK, ROOSEVELT WARREN, and JOEL HENDRIX operated Tow Guys, nc. and/or KBR Auto; and whereby ROBERT MILK, ROOSEVELT WARREN, and JOEL HENDRIX acted sagen of sit ens andor bined monies froma bank ascount inthe sane of si ents 28 land whereby ROBERT MILK, ROOSEVELT WARREN, and/or JOEL HENDRIX falsely appended Flying O Mini Storage” and/or “Brandon Crawford” to lien sale documents; and whereby JOEL | HENDRIX falsely claimed to have attended alien sale; and/or (3) pursuant to « conspiracy to committhis crime, with the intent that the crime be committed; knowingly offered for filing with the) Department of Motor Vehicles a “Lien Sale Affidavit” and/or “Lien Claimant's Certification” for a 2012 Dodge Challenger, bearing VIN 2C3CDYBT9CH145615, knowing said documents to be fas, which documents-tf genuine might be fled with the Department of Motor Vehicles under the laws of| ne State of Nevada, {All of which constitutes the crime of OFFERING FALSE INSTRUMENT FOR FILING OR| RECORD, a category “C” felony in violation of NRS 239.330. 7 COUNT ‘CATEGORY “C” Felony - NRS 239.330 Defendants ROBERT MILK, KENNETH JOHNSON, and CURTIS ACREE, in the County of Clark, State of Nevada, ether by virtue of their own actions or by the actions of their agents or employees, without lawful authority, knowingly procured or offered a false instrument to be filed, to wits (On or about June 5, 2014, Defendants ROBERT MILK, KENNETH JOHNSON, and CURTIS| | ACRE, without lawful authority, with the Defendants being criminally liable under one or more ofthe following principles of criminal liability, to-wit: (1) by directly committing this crime; and/or (2) by aiding or abetting in the commission ofthis crime, with the intent that this crime be committed, by providing counsel and/or encouragement and by entering into a course of conduct whereby KENNETH JOHNSON owned or opersied NV Ranch dba Statewide Towing, and/or CURTIS ACREE owned or [operated Towing Jamison dba Statewide Towing, and whereby ROBERT MILK and KENNETH JOHNSON acted as agents of said entities andlor received monies from a bank account in the name of seid entities; and/or (3) pursuant to @ conspiracy to commit this crime, withthe intent that te crime be] committed; knowingly offered for filing wth the Department of Motor Vehicles a “Lien Sale Affidavit” andlor & “Lien Claimant's Certification” for a 2007 Lexus LS, bearing VIN JTHBL46577S046083 knowing said documents to be false, which documents if genuine might be filed with the Department of| Motor Vehicles under the laws ofthe State of Nevada. [All of which constiutes the crime of OFFERING FALSE INSTRUMENT FOR FILING OR|RECORD, a category “C” felony in violation of NRS 239.330. E INSTI ‘CATEGORY “C” Felony - NRS 239.330, Defendants ROBERT MILK, ROOSEVELT WARREN, and JOEL HENDRIX, in the County lof Clark, State of Nevada either by virtue of their own actions or by the ations of th gents or emplyecs, without lawful authority knowingly procured or offered false instrument tobe fle o it (On or about Februry 7, 2017, Defendants ROBERT MILK, ROOSEVELT WARREN, and JOEL HENDRIX, without lawful authority, with te Defendants being criminally lable under one or more ofthe following principles of criminal Habit, to-wit (1) by dieely commiting this exe; and/or (2) by aiding or abetting in the commission of this crime, withthe intent dha this erie be committed, by proving counsel andlor encouragement and by entering into a course of conduct whereby ROBERT MILK, ROOSEVELT WARREN, and JOEL HENDRIX operated Tow Guys, Ine. andlr KBR Auto; and whereby ROBERT MILK, ROOSEVELT WARREN, and JOEL HENDRIX acted a agent of sid entities and/or obtained monies from a bank account inthe name of sid ests and whereby ROBERT MILK, ROOSEVELT WARREN, andor JOEL HENDRIX falsely appended Flying © Mini Storage” andor “Brandon Crawford” wo Tien sale documents; andor (3) pursuant 8 consprecy to commit this crime, withthe intent thatthe crime be commited; knowingly offered for fling with the Department of Motor Vehicles a “Lien Sale Affidavit” andor a “Lien Claimant's | Cerifcatin” fora 2015 Mercedes, bearing VIN WDDXI8FBXFAOO9106, owing sid documents 0 be fils, which documents if genuine might be fled withthe Department of Motor Vehicles under the laws ofthe State of Nevada. {Al of which constitutes the crime of OFFERING FALSE INSTRUMENT FOR FILING OR| RECORD, a category “felony in violation of NS 239.330.1 Defendants ROBERT MILK, KENNETH JOHNSON, and CURTIS ACRE, in the County of| (Clark, State of Nevada, citer by virtue of their own actions or by the actions of their agen a employees, without lawful authority, knowingly, by false pretense, obtained from any other person ay |money, goods, wares, chattels, or other valuable thing, with the intent to cheat or defraud the other person, and the vale of sidthing was $650 oF more, to wit: (On or about August 25, 2014, Defendants ROBERT MILK, KENNETH JOHNSON, ax ICURTIS ACRE, without ivful thority, with the Defendants being criminally Hable under on or more of the following principles of criminal ibility, to-wit: (1) by directly commiting this eine and/or (2) by aiding or abeting in the commission of this crime, with the intent that this crime be| 10 ||committed, by providing counsel and/or encouragement and by entering into a course of conduct 11 || whereby KENNETH JOHNSON oved or operated NV Ranch dbe Statewide Towing, and/or CURTIS 12 || ACREE owned or operated Towing Jamison dba Statewide Towing; and whereby ROBERT MILK and 13 || KENNETH JOHNSON acted as agents of said entities andlor received monies from a bank account in 14 || tne name of said entities; and whereby CURTIS ACREE offered false documents for filing; andor (3) 15 ||pursuant to a conspiracy to commit this crime, with the intent that the crime be committed; knowingly 16 |) and designedly offered for fling with the Department of Motor Vehicles a “Lien Sale Affidavit” and/or 17 l]a “Lien Claimant's Certification” for a 2007 BMW, bearing VIN WBXPC934X7WI02201, which 18 || documents misrepresented tat Defendants and/or their agents or employees had sent required noice to 19 ||Ccalifornia Auto Finance, thereby obtaining a security interest in said vehicle by false pretense, withthe 20 || value of said vehicle and/or security interest being $650 or more. a {All of which consttates the crime of OBTAINING MONEY OR PROPERTY UNDER FALSE, 22 || PRETENSES, a category “B” felony in violation of NRS 205.380. COUNTS Fi ‘CATEGORY “B” felony - NRS 205.380 2s 6 Defendants ROBERT MILK, KENNETH JOHNSON, and CURTIS ACREE, inthe County f| 27 ||Clark, State of Nevada, eier by virtue of their own actions or by the actions of their agents of 28 ||employees, without lawful authority, knowingly, by false pretense, obtained from any other person any +money, goods, wares, chatels,or ter valuable thing, with the intent fo cheat or deftaud the hr person, andthe valu of sid thing was $680 or mor 0 Wit (On or about June 16,2014, Defendants ROBERT MILK, KENNETH JOHNSON, and CURTIS ACRE, without lawful authority, wih the Defendants being criminally Iinble under one or mor ofthe following principles of criminal ibility, to-wit (1) by direc commiting this crime; andor (2) by siding or abting in the commissen of this crime, with the intent that this rime be commited, by a course of conduct whereby KENNETH] providing counsel and/or encouragement and by entering JOHNSON owned or operated NV Ranch dbs Statewide Towing, and/or CURTIS ACREE owned or operated Towing Jamison dba Stwewide Towing; and whereby ROBERT MILK and KENNETH] JOHNSON acted as agents of said entities andlor received monies from a bank account in the name of] said entities; end/or (3) pursuant to a conspiracy to commit this crime, with the intent thatthe crime be committed; knowingly and designedly offered for filing wth the Department of Motor Vehicles a “Lien Sale Affidavit” and/or a “Lien Claimant's Cerfication” for a 2013 Ford Taurus, bearing. VIN} IFAHP2KT3DG136398, which documents misrepresented that Defendants and/or their agents or| employees had sent required notice to Ford Motor Credit, thereby obtaining @ security interest in ssid vehicle by false pretense, with the value of said vehicle and/or security interest being $650 or more. [All of which constitutes the crime of OBTAINING MONEY OR PROPERTY UNDER FALSE, PRETENSES, a category “B” felony in violation of NRS 205.380. 10 NEY OR PR ‘CATEGORY “B” felony - NRS 205.380 Defendants ROBERT MILK, KENNETH JOHNSON, and ROOSEVELT WARREN, in th| County of Clark, State of Nevada, ether by virtue of their own actions or by the actions oftheir gents or employees, without lawful authority, knowingly, by false pretense, obtained from any other perso any money, goods, wares, chattels, or other valuable thing, with the intent to cheat or defraud the othe Petson, andthe value of said thing was $650 or more, to wit (On or about November 5, 2013, Defendants ROBERT MILK, KENNETH JOHNSON, and [ROOSEVELT WARREN, without lawful authority, withthe Defendants being criminally liable under10 2 B 6 1s 16 "7 18 9 20 a 2 Py 25 Fa 28 lone oF more of the following principles of criminal libi crime; andlor 2) by aiding or abetting inthe commission of this rime, with the intent that this crime be commited, by providing counsel andor encouragement and by entering iso a couse of condut| whereby KENNETH JOHNSON owned or operated NV Ranch In. andlor Aquarius Towing andor NVT Storage and ROOSEVELT WARREN claimed to be a registered owner, and whereby ROBERT MILK and KENNETH JOHNSON acted as agents of sid entes andor obtained or used monis from a bank account in the name of ssid ens; and wherhy KENNETH JOHNSON offered fle documents for filing; and/or (3) pursuant oa conspiracy to commit this crime, withthe intent tat he crime be commited; knowingly and desgnedly offered for fling with the Deparment of Motor Vehicles a “Lien Sale Affidavit” andlor a “Lien Claimants Cerfiction” fr a 2008 Toyota Siena, bearing VIN STDZK22068S135805, which documents misrepresented tet Defendants andor thei agents or employees hal sent sequed notice to Toyota Motor Credit therby obinining » sscuty interest in sid vehie by false pretense, with the valu of sid vehicle andor security interest being $650 or more {All of which consites the crime of OBTAINING MONEY OR PROPERTY UNDER FALSE| PRETENSES, eatgory“B” felony in violton of RS 205.80. COUNT LL ‘CATEGORY “B” felony -NRS 205.380 Defendant ROBERT MILK, inthe County of Clat, State of Nevade, without lvful authority, knowingly, by false pretense, obtained from any other person any money, goods, wares, chats, or other valuable thing with the intent to cheat or defraud the other person, end the value of said thing was $650 or more, to wit On or about September 9, 2016, Defendant ROBERT MILK knowingly and designedly provided false information on loan documents submited to TD Auto Finance and/or Chapman Dodee, in order to obtain a 2016 Dodge Ram bearing VIN 3C63RRHLSGG278217, which documents misrepresented Defendants financial condition and/or source of income ard/or employment andor residence, thereby obtaining an interest in sid vehicle by false pretense, with the value of sui vehicle10 u 13 “4 18 ” 18 19 20 a 2 2 4 27 28 andor interest being $650 or more. [All of which constitutes the crime of OBTAINING MONEY OR PROPERTY UNDER FALSE] PRETENSES, a category “B” felony in violation of NRS 205,380. ‘BURGLARY CATEGORY “B” felony - NRS 205.060 (On or about September 9, 2016, Defendant ROBERT MILK, in the County of Clark, State of| Nevada, di then and there willfully, unlawfully, and feloniously enter, with intent to commit a felony, to wit: Obtaining Money or Property by False Pretense, that certain building occupied by Chapman Dodge, located at 3175 East Sahara Avenue, Las Vegas, Clark County, Nevada. [All of which constitutes the crime of BURGLARY, a category “B” felony in violatin of NRS| 205.060, COUNTI3. GMC 3 PRE! ‘CATEGORY “B” felony - NRS 205.380 Defendants ROBERT MILK, ROOSEVELT WARREN, and JOEL HENDRIX, inthe County of Cla, Stat of Nevads ether by vitue oftheir own actions or by the actions of their agents or employees, without lawl authority, knowingly, by false pretense, obtained from any other person eny| money, goods, ware, chattels, or other valuable thing, with the intent to cheat or defaud the othe person, and the value of said thing was $650 or more, to wit: (On or abcut September 6, 2016, Defendants ROBERT MILK, ROOSEVELT WARREN, and JOEL HENDRIX, without lawful authority, with the Defendants being criminally liable under one ot more of the following principles of criminal liability, to-wit: (1) by directly committing this erime; and/or (2) by sicing or abeting in the commission of ths crime, with the intent that this eime be committed, by providing counsel and/or encouragement and by entering into a course of conduct whereby ROBERT MILK, ROOSEVELT WARREN, and JOEL HENDRIX operated Tow Guys, In. andlor KBR Auto; and whereby ROBERT MILK, ROOSEVELT WARREN, and JOEL HENDRIX ected as agents of sid entities and/or obtained monies from a bank account inthe name of sid entities land whereby ROBERT MILK, ROOSEVELT WARREN, andlor JOEL HENDRIX falsely appended oeWestside Auto & Storage” and/or “David Smith” and/or “Tow Guys” to lien sale documents; andor () pursuant to @ conspiracy to commit this crime, with the intent thatthe erime be commited; knowingly and designedly offered for filing with the Department of Motor Vehicles a “Lien Sale| |Affidavit” and/or a “Lien Claimant's Certification” for a 2014 BMW 7501, bearing VIN} WBAYASCSOEDSI5400, which documents misrepresented that Defendants and/or their agents of Jemployees obtained said vehicle via auction, thereby obtaining an interest in said vehicle by fils pretense, with the value of said vehicle andor interest being $650 or more. [All of which constitutes the crime of OBTAINING MONEY OR PROPERTY UNDER FALSE PRETENSES, a esegory “B” felony in violation of NRS 205.380. OBTAINING MONEY OR PROPERTY UNDER FALSE PRETENSES y ‘CATEGORY “B” felony - NRS 205.380 Defendants ROBERT MILK, ROOSEVELT WARREN, and JOEL HENDRIX in the County of| Clark, State of Nevada, either by virtue of their own actions or by the actions of their agen of employees, without lawful authority, knowingly, by false pretense, obtained from any other person any money, goods, wares, chattels, or other valuable thing, with the intent to chest or defraud the cher person, and the value of said thing was $650 or more, to wit (On or about February 1, 2017, Defendants ROBERT MILK, ROOSEVELT WARREN, ond [JOEL HENDRIX, without lawful authority, with the Defendants being criminally liable under ove or more of the following principles of criminal liability, to-wit: (1) by directly committing this cximes and/or (2) by aiding or abetting in the commission of this crime, with the intent that this crime be| committed, by providing counsel and/or encouragement and by entering into a course of conduct whereby ROBERT MILK, ROOSEVELT WARREN, and JOEL HENDRIX operated Tow Guys, Ic. and/or KBR Autc; and whereby ROBERT MILK, ROOSEVELT WARREN, and JOEL HENDRIX) acted as agents of sid entities and/or obtained monies from a bank account inthe name of said entities; Jand whereby ROBERT MILK, ROOSEVELT WARREN, and/or JOEL HENDRIX falsely appended) Flying O Mini Storage” and/or “Brandon Crawford” to lien sale documents; and whereby JOEL HENDRIX falsely claimed to have attended alien sale; andor (3) pursuant to @ conspiracy to commit a2his ime, with he intent the eine be commited: Knowingly ad signed offed fr Hi ih the Dearne of Moor Veides «Lien Sle Afi anor « “Lien Chinas erin’ for 2012 Dodge Cage, earng IN 2C3CDYBTICHIAS65, which docunes misrepresented that Defendants and/or their agents or employees obtained said vehicle via auction, heb obihng an interest in sid hice by ise pees, wit he value of si ese and net being $550 oF moe ‘othe onset crine of OBTAINING MONEY OR FROPERTY UNDER FALSE PRETENSES, category“ flonynvoaon of RS 208.380, OPERTY UNDE CATEGORY" floy RS 205380 Defeats ROBERT MILK, KENNETH JOHNSON, and CURTIS ACREE in the Cus of cack, Site of Nevada, eer by vite of tr own aon or bythe sons of thei apes copays, witht ew auboriy, owing, by fle pretense, oblnd fom any le eon ay none, gots, wars, chat, oor vl thing wth he nent chat def he te penn, ante vale fd thing as8450 oF moe, owt (nor bout Jane 5,204, Defendants ROBERT MILK, KENNETH JOHNSON, en CURTIS ACREE, witow on asboriy, wit he Defends xing riminly ate under oe or mare of sowing nips of rnin nhiy, -wt: (1) by ety commiting his ime; andor by iig or stein in the commision of seine, with he net at isin be commited by roving couse! anor ecouragamas ed by eting ino a eoune of cont why KENNETH JOHNSON onned or opened NV Rach da Sewide Towing, andlor CURTIS ACREE owned ented Towing Janson dba Suevide Towing: and wherhy ROBERT MILK and KENNETH JORDON sted as gens f si ents enor recived monies om tk account in th name of ni ene ano) psa oa onspinzy o com his rine, with te inte hat the cine smi nwngy and designed fee olin with he Deparinent of Motor Vices Lin sue Ata” aor « “Lien China's Cerin” for # 2007 Les 15, berg VIN STMBLAGFYSO46ED, which documents miseprsenied tat Dende andor tir apes ot asemployees had sent required ntie to Toyota Motor Credit, thereby obtaining a secur itrestin sid vehicle by false pretense, withthe value of sid vehicle andor security interest being $650 or more [All of which consitites th crime of OBTAINING MONEY OR PROPERTY UNDER FALSE PRETENSES, a ctegory“B” felony in violation of NRS 205.380. OBTAINI PREI CATEGORY 3° ony -NRS 20530 Defendants ROBERT MILK, ROOSEVELT WARREN, and JOEL HENDRIX in he County of Clark, State of Nevada, citer by vinue of their own actions or by the actions of thir agents or employees, without lawful authority, knowingly, by flse pretense, obtained from any other person any money, goods, wares, clatels, or other valuable thing, withthe intent to cheat or defraud the he person, andthe value of sid thing was $650 or moe, o wit; (On or about February 7, 2017, Defendants ROBERT MILK, ROOSEVELT WARREN, and JOEL HENDRIX, without lawful authority, with the Defendants being criminally liable under one or} more of the following pineipls of criminal liability, to-wit: (1) by directly committing this crim; and/or (2) by sing or abetting in the commission ofthis crime, with the iment that tis evime be committed, by providing counsel and/or encouragement and by entering into a course of conduct) whereby ROBERT MILK, ROOSEVELT WARREN, and JOEL HENDRIX operated Tow Guys, In. and/or KBR Auto; and whereby ROBERT MILK, ROOSEVELT WARREN, and JOEL HENDRIX| acted as agents of sud entities andlor obtained monies from a bank account inthe name of sid ents and whereby ROBERT MILK, ROOSEVELT WARREN, andlor JOEL HENDRIX fassly appended Flying © Mini Storage” and/or “Brandon Crawford” to len sale documents; and/or (3) pursuant to a [conspiracy to commit this crime, with the intent that the crime be committed; krowingly and) esigndly offered for filing with the Deparment of Motor Vehicles a “Lien Sale Affiivt” andor a Lien Claimant's Certfcation” for a 2015 Mercedes, bearing VIN WDDXI8FBXFA009106, which [documents misrepresenced that Defendants and/or their agents or employees and/or a third party [obtained said vehicle via auction, thereby obtaining an interest in said vehicle by false pretense, with the value of suid vehicle and/or interest being $650 or more.1 All of which constitutes the crime of OBTAINING MONEY OR PROPERTY UNDER FALSE, PRETENSES, a category “B” felony in violation of NRS 205.380. COUNT17 )BTAINI ‘UNDER FAL! ‘CATEGORY “B® felony - NRS 205.380 2 3 4 5 6 Defendants ROBERT MILK, CURTIS ACRE, and ROOSEVELT WARREN, in the County 7 lot Clark, State of Nevada, either by virtue of their own actions or by the actions of their agents or 8 | employees, without lawful authority, knowingly, by false pretense, obtained from any other person any 49 || money, goods, wares, chattels, or other valuable thing, with the intent to cheat or defraud the other 10 |] person, and the value of said thing was $650 or more, to wit: n On or about November 15 2014, Defendants ROBERT MILK, CURTIS ACREE, and 12 || ROOSEVELT WARREN, without lawful authority, wth the Defendants being criminally liable unde 13 |one or more of the following principles of criminal liability, w-wit: (1) by directly commiting this 14 |) crime; and/or (2) by aiding or sbettng in the commission ofthis crime, with the intent that this crime be 15 |)committed, by providing counsel and/or encouragement and by entering into a course of conduc 16 || whereby ROBERT MILK, CURTIS ACREE, and ROOSEVELT WARREN operated Tow Guys, Ine 17 [and/or State Wide Towing and/or Roosevelt Cash for Cars Inc. and/or Towing Jamison Inc, and/or 18 || Great Buy, and whereby ROBERT MILK, CURTIS ACREE, and ROOSEVELT WARREN acted 83 19 | agents of said entities and/or obtained monies ftom a bank account in the name of said entities, and 20 || whereby ROBERT MILK and ROOSEVELT WARREN provided insufficient ttle to Carlos Penagos| 21 ||after received money in exchange for said tile; and/or (3) pursuant to s conspiracy to commit this 22 ||erime, with the intent thatthe crime be committed; knowingly and designedly sold a vehicle to Carlos 23 |}penagos, to-wit: a 2014 Nissan Sentra, bearing VIN 3N1AB7APOEL60898, with Defendants and/or 24 ||their agents or employees misrepresenting that they would provide legally sufficient ttle for said 25 || vehicle to Carlos Penagos, thereby obtaining cash by false pretense, with the value of ssid cash being 26 || $650 or more a {All of which constitute the crime of OBTAINING MONEY OR PROPERTY UNDER FALSE, 28 || PRETENSES, a category “B” felony in violation of NRS 205.380. -S-COUNT (AL IDE iG ‘CATEGORY “B” felony ~ NRS 205.463 Defendant ROOSEVELT WARREN, in the County of Clark, State of Nevada, without lawl authority, obtained personal identifying. information of another with the intent to commit an unlawful act, andlor used the personal identifying information for an unlawful purpose, including, without limitation, to obtain credit, a good, a service, or anything of value inthe name ofthat person, to wit (On or about June 16, 2016, Defendant ROOSEVELT WARREN, without lawful eutority, used] the social security number XXX-XX-9368, rightfully belonging to another person, at Wells Fargo Bank, located at 801 North Rancho Drive, Las Vegss, Nevada, in order to cash a check, All of which constitutes the crime of OBTAINING AND USING PERSONAL IDENTIFYING INFORMATION OF ANOTHER, a category “B” felony in violation of NRS 205.463. COUNTI9 ‘CATEGORY “B” felony —NRS 205.463, Defendant ROOSEVELT WARREN, ia the County of Clark, State of Nevada, without lawful authority, obtained personal identifying information of another with the intent to commit an unlewful act, andor used the personal identifying information for an unlawful purpose, including, without limitation, to obtain credit, a good, a service, or anything of valve inthe name ofthat person to wit On or about December 29, 2014, Defendant, ROOSEVELT WARREN, without lawful authority, used the social security number XXX-XX-6391, rightfully belonging to another person, at Bank of America, located at 801 North Nellis Boulevard, Las Vegas, Nevada, in order to withdraw ash, [All of which constitutes the erime of OBTAINING AND USING PERSONAL IDENTIFYING] INFORMATION OF ANOTHER, a category “B” felony in violation of NRS 205.463, OBTAINING AND USING PERSONAL IDENTIFYING INFORMATION OF ANOTHER, ‘CATEGORY “B” felony ~ NRS 205.463 Defendant, ROOSEVELT WARREN, in the County of Clark, State of Nevada, without lawfulaubority,obtsined personal identifying information of another withthe tent to commit an unlawful act, and/or used the personal identifying information for an unlawful purpose, including, witout imitation, to obtain credit, a good, a service, or anything of value in the nem ofthat person, 0 wit n or about October 23, 2015, Defendant, ROOSEVELT WARREN, without lyl author ased the social security number XXX-XX-6888, rightfully belonging to enther person, at Bank of America, located at 48101 West Charleston Boulevard, Las Vegas, Nevada inorder to withdraw cash All of which constitutes the rime of OBTAINING AND USING PERSONAL IDENTIFYING INFORMATION OF ANOTHER, category “B” felony in voltion of NRS 205 463 counrai )RMATION OF. ‘CATEGORY “B” felony - NRS 205.463 Defendant, ROOSEVELT WARREN, in the County of Clark, State of Nevada, without lawl authority, obtained personal identifying information of another with the intent to commit an unlawfl ‘ct, and/or used the personal identifying information for an unlawful purpose, including, without limitation, to obtain credit, a good, a service, or anythin of vale in the name ofthat person, to wit: ‘On or about September 15, 2015, Defendant ROOSEVELT WARREN, without lawful authority, used the social security number XXX-XX-£398, rightfully belonging to another person, at Bank of America, located at 801 North Nellis Boulevard, Las Vegas, Nevade, in order to deposit and/or withdraw cash, {All of which constitutes the crime of OBTAINING AND USING PERSONAL IDENTIFYING] INFORMATION OF ANOTHER, # category “B” felony in violation of NRS 205.463. SEES Ond oa ay NES 208.463 Defendant ROOSEVELT WARREN, in the County of Clark, Sate of Nevada, without awful authority, obtained personal Mdentifying information of another with the intent to comin an unlawful ect, andlor used the personal identifying information for an unlawful purpose, including, without imitation, to obtain cet, a good, a service, or anything of valu in the nme of tat person, to wit: “I‘On or about January 12, 2015, Defendant ROOSEVELT WARREN, without law authori, ased the social security number X0K-XX.9378, rightfully belonging to anther person, at Bank of| | America, lated at 801 Norh Nelis Boulevard, Las Vegas, Nevada, in order to withdraw cash All of which constitutes the crime of OBTAINING AND USING PERSONAL IDENTIFYING INFORMATION OF ANOTHER, category “B” felony in violation of NRS 205.463, OB: NAL. ‘CATEGORY “B” felony — NRS 205.463, Defendant ROOSEVELT WARREN, inthe County of Clark, State of Nevada, without iavfu authority, obtained personal identifying information of another with the intent commit an univ act, andor used the personal identifying information for an unlewful purpose, including, without imitation, to obtain credit, god, a service, or anything of vale inthe name of hat person to wit (On or about October 9, 2015, Defendant ROOSEVELT WARREN, without lewfl author, used the soil security number XXX-XX.9781, rightfully belonging to another person, at Bank of| America, located at 801 North Nellis Boulevard, Las Vegas, Nevada inorder to cash check, {All of which constitutes the crime of OBTAINING AND USING PERSONAL IDENTIFYING [INFORMATION OF ANOTHER, a category “B” felony in violation of NRS 205.463. GP ‘CATEGORY “B” felony ~ NRS 205.463, Defendant ROOSEVELT WARREN, in the County of Clark, State of Nevada, without lavfl authority, obtained personel identifying information of another withthe intent to commit an unlawfil ‘ct, andlor used the personal identifying information for an unlawful purpose, including, without limitation, to obtain credit a good, a servic, or anything of value inthe name ofthat person to wit (On or about August &, 2016 Defendant ROOSEVELT WARREN, without lawful authority, rased the social security number 300CXX9949, rightfully belonging to another person, at Bank of| | America, located at 801 Nerth Nellis Boulevard, Las Vegas, Nevada, in order to withdraw cash All of which constiutes the crime of OBTAINING AND USING PERSONAL IDENTIFYING 18.INFORMATION OF ANOTHER, a category “B” felony in violation of NRS 205.463. COUNT25 iURG! CATEGORY “B” felony - NRS 205.060 (On or about Jure 16, 2016, Defendant ROOSEVELT WARREN, in the County of Clark, State lof Nevada, did then and there willfully, unlawfully, and feloniously enter, with intent to commit a felony, to wit: Obtaining and Using Personal Identifying Information of Another, that certain building occupied by Wells Fargo Bank, located at 801 North Rancho Drive, Las Vegas, Nevada All of which constitutes the crime of BURGLARY, a category “B” felony in violation of NRS| 205.060. COUNT 26 BURGLARY CATEGORY “B? felony - NRS 205,060 (On or about December 29, 2014, Defendant ROOSEVELT WARREN, in the County of Clark, State of Nevada, did then and there willfully, unlawfully, and feloniously enter, with intent to commit a felony, to wit: Obtaining and Using Personal Identifying Information of Another, that certain building | occupied by Bank of America, located at 801 North Nellis Boulevard, Las Vegas, Clark County, Nevada. {All of which constitutes the crime of BURGLARY, a category “B” felony in violation of NRS\ 205.060. COUNT 27 ‘BURGLARY CATEGORY “B” felony - NRS 205.060 (On or about October 23, 2015, Defendant ROOSEVELT WARREN, in the County of Clark, State of Nevada, did then and there willfully, unlawfully, and feloniously enter, with intent to commit a felony, to wit: Obtaining and Using Personal Identifying Information of Another, that certain building occupied by Bank of America, located at 48101 West Charleston Boulevard, Las Vegas, Clark Count, | Nevada. All of which constitutes the crime of BURGLARY, « category “B” felony in violation of NRS\ 205.060.COUNT 28 BURGLARY CATEGORY “B” felony -NRS 205,060 (On or about September 15, 2015, Defendant ROOSEVELT WARREN, in the County of Ca, tue of Nevada, did then ad there wllfly, unlawflly, and floniousy ener, wit intent to commit felony, to-wit: Cbiaining and Using Personal Identifying information of Another, that certain building occupied by Bank of America, located at 801 North Nelis Boulevard, Las Vegas, Clark Couns, Nevada. All of which consites the erie of BURGLARY, category “B” felony in violation of NRS| 205.060. 10 ‘COUNT 29 ‘BURGLARY CATEGORY “B” felony - NRS 205.060 2 (On or about January 12, 2015, Defendant ROOSEVELT WARREN, in the County of Cla, 13 || tate of Nevada, did then and there wilfully, unlawfully, and feloniously eter, with intent to commit a 14 ||felony, to wit: Obtaining and Using Personal Identifying Information of Another, that certain building | 15 lJoccupied by Bank of America, located at 801 North Nellis Boulevard, Las Vegas, Clark County, 16 || Nevada. ” ‘All of which constitutes the crime of BURGLARY, a category “B” felony in violation of NRS 18 |] 205.060. iy counrs0 ‘BURGLARY, “ CATEGORY “B? felony -NRS 205.060 2 (On or shout October 9, 2015, Defendant ROOSEVELT WARREN, in the County of Cla 22 || State of Nevads did then and there wilflly, unlawfully and feloniously enter, with intent to commit 23 || felony, to wit: Obtaining and Using Personal Identifying Information of Another, that certain building 24 |loccupied by Bank of America, located at 801 North Nellis Boulevard, Las Vegas, Clark County, 25 || Nevada. 6 ‘All of which constitutes the crime of BURGLARY, 27 |}205.060. s category “B” felony 28 firsCOUNTS! ‘BURGLARY CATEGORY “B" felony - NRS 205.060 (On or about August 8, 2016, Defendant ROOSEVELT WARREN, inthe County of Clr, Ste of Nevada, did then and there wilfully, unlawfully, and feloniously enter, with intent to commit a felony, to wit: Obtaining and Using Personal Identifying Information of Another, that certin building oceuped by Bak of Americ, located at 801 North Nellis Boulevard, Las Vegas, Clark Coun, Nevada. {All of which constitutes the crime of BURGLARY, a category “B” felony in violation of NRS| 205.060. MORTGAGE LENDING FRAUD CATEGORY *C” felony ~NRS 205.372 Defendants, ROBERT MILK and KRISTI MILK, inthe County of Clark, State of Nevads without lawful authority, while acting as participants ine mortgage lending transaction, knowingly and unlawfully made one or more false statements or misrepresentations conceming a material fat, r| knowingly concealed or fed to disclose a material fat to wit nor about September 7, 2016, Defendants, ROBERT MILK and KRISTI MILK, submited to the Federal Housing Authority a Uniform Residential Loan Application, in which both ROBERT MILK | and KRIST MILK misrepresented that ROBERT MILK was employed by Tow Guys, Ine. for over two years, and/or misrepresented income and/or gifts endor the financial status of KRISTI MILK. andor ROBERT MILK. nit vi 0 nr i 7 i vi a[All of which constitutes the crime of MORTGAGE LENDING FRAUD, a category “C” felony in violation of NRS 205.372. DATED this _1St day of August, 2017. ADAM PAUL LAXALT ‘Attorney By; jel Weatmeyer Senior Deputy Attomey ENDORSEMENT: A Tre Bill 2