10 n Be er 18 9 20 a 2 a 4 25 26 u 28 IND Seta oR re Reven risa orencours ee eee | Nevada Bar Number 10273 eee) Las Vegas, NV 89101-1608 OCT 26 2016 ipa dwestmeyer@ag.nv.g0v Fle recat ‘Attorneys for the State of Nevada DISTRICT COURT CLARK COUNTY, NEVADA ‘THE STATE OF NEVADA, ) ) Plain, } CASENO: C-16318998-4 ) ws )-DEPTNO: 1x ) ROBERT MILK 1D#1261837 ) KENNETH JOHNSON [D#2584164 ) CURTIS ACRE 1D#3029209 ) land ROOSEVELT WARREN 1D#2722938——) ) Defendants d donc Re Herter ni iter hoet berate) INDICTMENT. Defendanis, ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, and ROOSEVELT WARREN, above named, are accused by the Grand Jury of heving commited thefllowing offenses: ‘OFFERING FALSE INSTRUMENT FOR FILING OR RECORD, a 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; POSSESSION OF STOLEN VEHICLE, a category /“B" felony in violation of NRS 205273; POSSESSION OF PERSONAL IDENTIFYING INFORMATION TO ESTABLISH FALSE STATUS OR IDENTITY, a category “BY felony in violation of NRS 205.465; POSSESSION OF CONTROLLED SUBSTANCE WITH INTENT TO| /SELL, a category “D" felony in violation of 453.337; PERJURY, a category “D" felony in violation of INRS 199,145; MULTIPLE TRANSACTIONS INVOLVING FRAUD OR DECEIT, a category “Btzg i i {elony, in violation of NRS 205.377; and RACKETEERING, a category “B” felony, in violation of| /NRS 207.400. All ofthe acs alleged herein have been committed or consummated on or between Jaly 2013 and January 2015, by the above-named Defendant, executed in whole or in prt within the County of| Clark, State of Nevada, inthe following manner counra FILING OR RECORD ‘Category *C” Felony ~ NRS 239.330 Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS ACRE, and ROOSEVELT| | WARREN, in the County of Clark State of Nevada, ether by virtue oftheir own actions or by the actions of their agents or employees, without lawful authority, knowingly procured or offered a false instrument tobe filed, to wit: On or about November 22, 2013, Defendants ROBERT MILK, KENNETH JOHNSON, |CURTIS ACRE, and ROOSEVELT WARREN, without lawful authority, with the Defendants being criminally liable under one or more of the following principles of eximinal Liability, to-wit (1) by’ directly coramitting this crime; andor (2) by aiding or abetting inthe commission ofthis crime, with the intent that this exime be committed, by providing counsel and/or encouragement and by entering, into a course of conduct whereby ROBERT MILK, KENNETH JOHNSON, CURTIS ACRE, and| J ROOSEVELT WARREN operated Tow Guys, Inc. and/or State Wide Towing and/or NV Ranch Inc and/or NVT Storage and/or ASAP Towing and/or Roosevelt Cash for Cars Inc. and/or Towing Jamison inc. and/or Aquarius Towing and/or Great Buy, and whereby ROBERT MILK, KENNETH, JOHNSON, CURTIS ACREE, and ROOSEVELT WARREN acted as agents of stid entities and/or obtained monies from a bank account in the name of said entities; andlor (3) pursuant toa conspiracy to ‘commit this crime, with the intent thatthe crime be committed; knowingly offered for fling with the [Department of Motor Vehicles @ “Lien Sale Affidavit” andi a “Lien Claimant's Cerifiaton” fora 12005 Pontias Aztec, bearing VIN 3G7DA03E05SS06562, 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 constitutes the crime of OFFERING FALSE INSTRUMENT FOR FILING OR}10 n 18 19 a 2 2 4 25 26 n 28 RECORD, a category “C” felony in violation of NRS 239 330. COUNT. Category *C” Felony -NRS 239330 Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, and ROOSEVELT WARREN, inthe County of Cla, State of Nevada, either by vite oftheir ow actions of bythe actions of ther agents or employees, without lawful authority, knowingly procured or offed a fae instrument to be le, to wit (On or about September 17, 2013, Defendants ROBERT MILK, KENNETH JOHNSON, ]CURTIS ACREF, ad ROOSEVELT WARREN, without lawful auorty, withthe Defendant being criminally Tiale under one ot more ofthe following prinsples of criminal ibility, to-wit: (1) by iectly commiting this erime; andor (2) by aiding or abeting in the commission ofthis cme, with the inten that this ime be committed, by proving counsel andor encouragement and by entering into-a couse of conduct whereby ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, an ROOSEVELT WABREN operated Tow Guys, In. andr State Wide Towing andlor NV Ranch Ine. andlor NVT Storgeand/or ASAP Towing andor Roosevelt Cash for Cas Inc. and/or Towing Jamison Inc. andor Aquarias Towing andor Great Buy, and whereby ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, and ROOSEVELT WARREN acted as agents of suid ents and/or obtained monies froma bank acount inthe name of sid entities andlor (3) pursuant toa conspzsy to commit this crime, with the inten that the crime be commit; knowingly offere for fing withthe Deparment of Motcr Vehicle a “Lien Sale Affidavit" andra “Lien Claimants Certifstin” for & 2006 Pontiac Tore, bearing VIN 2CKDLS3#166096833,krowing sud documents tobe fils, which documents if genuine might be filed with the Department of Motor Vehicles under the laws of the State of Nevada; {All of which consttats the crime of OFFERING FALSE INSTRUMENT FOR FILING OR RECORD, a category “C" felony in violation of NRS 239330. O O a10 n R trey Gees Oe 18 9 20 a1 n 2 4 25 26 u 28 couNT3, iG FALSE. FILING ‘Category “C” Felony - NRS 239.330 Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS ACRE, and ROOSEVELT WARREN, inthe County of Clark, State of Nevada, ether by vit oftheir own actions or bythe setions of thir agents or employees, without lawful authority, knowingly procul or offre fuse instrument tobe filed to wit (On or sbout July 25, 2014, Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS | ACREE, and ROOSEVELT WARREN, without lawful authority, withthe Defendants being criminally ity, to-wit (I) by directly table under one or more of the following principles of eximina! lis commiting his crime; andor (2) by sing or abeting inthe commission of this rie, with the intent that this crime be committed, by providing counsel andor encouragement and by eterng into a course of conduct whereby ROBERT MILK, KENNETH JOHNSON, CURTIS ACRE, and ROOSEVELT WARREN operated Tow Guys; Ine. andlor Sate Wide Towing and/or NV Ranch Inc. andlor NVT Stonge andlor ASAP Towing andor Roosevelt Cash for Cas Ic. andor Towing ‘amison Ie. andor Aquarius Towing andor Great Buy and whereby ROBERT MILK, KENNETH JOHNSON, CURTIS| [ACREE, and ROOSEVELT WARREN acted a agents of sid entities andor obtined moni from a bank account in the name of said entities; and/or (3) pursuant oa conspiracy o commit this crime, with the intent that the crime be committed; knowingly offered fr fing with the Department of Motor andor a “Lien Claiman’s Certification” fora 2001 Lincoln LS, [Vehicles a “Lien Sale Affidavit bearng VIN ILNHMS7A71Y617673, 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 constitutes the crime of OFFERING FALSE INSTRUMENT FOR FILING OR RECORD, a category “C” felony in violation of NRS 239.330, COUNT 4 R, ‘Category “C” Felony - NRS239.330 er, Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS ACRE, and ROOSEVELT WARREN, in the County of Clark, State of Nevada, either by virtue of their owe actions or by the actions of their agents or employees, without lawful authority, knowingly procured or offered a false10 u 18 0 20 a 2 a 2s 26 7 28 instrument tobe filed, to wit: On or about August 9, 2014, Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS /ACREE, and ROOSEVELT WARREN, without lawful authority, with the Defendants being criminally | liable under one or more of the following principles of crntinal liability, to-wit: (1) by directly committing this crime; andor (2) by aiding or abetting in the commission ofthis erime, withthe intent that this crime be committed, by providing counsel and/or encouragement and by entering ito a course of conduct whereby ROBERT MILK, KENNETH JOHNSON, CURTIS ACRE, and ROOSEVELT WARREN operated Tow Guys, Inc. and/or State Wide Towing andlor NV Ranch Ine. and/or NVT} Storage andlor ASAP Towing and/or Roosevelt Cash for Cars Inc. and/or Towing Jamison lnc, and/or Aquarius Towing and/or Great Buy, and whereby ROBERT MILK, KENNETH JOHNSON, CURTIS JACREE, and ROOSEVELT WARREN acted as agents of suid entities andlor obtained monies fom a| bank account inthe name of said entities; and/or (3) pursuant oa conspiracy to commit this crime, with the intent thatthe crime be committed; knowingly offered for filing with the Department of Motor Vehicles a “Lien Sale Affidavit" andlor a “Lien Claimant's Certification” for a 2000 Cala Deville bearing VIN 1G6KDS¢Y4YUI7#283, Inowing std documents to be file, which documents if genuine might be ied with the Department of Motor Vehicles under the laws ofthe Stat of Neva, {All of which constitutes the crime of OFFERING FALSE INSTRUMENT FOR FILING OR RECORD, a category “C” felony in violation of NRS 239.330. cours OFFERING WN mR tegory “C” Felony - NRS 239.330, Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS ACRE, and ROOSEVELT WARREN, in the County of Clark, State of Nevada, eithe by virtue oftheir own actions or by the actions oftheir agents or employees, without lawful authority, knowingly procured or offered a false instrument tobe filed, to wit: (On or about May 26, 2014, Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS| /ACREE, and ROOSEVELT WARREN, without lawful authority, with the Defendants being criminally liable under one or more of the following principles of criminal lability, 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 proving counsel and/or encouragement and by etring into course of conduct whereby ROBERT MILK, KENNETH JOHNSON, CURTIS ACRE, and ROOSEVELT| WARREN operated Tow Guys, Inc, andlor State Wide Towing and/or NV Ranch Inc. andor NVT| Storage andor ASAP Towing and/or Roosevelt Cash for Cars Ine. andlor Towing Jamison tn. andor Aquarius Towing and/or Great Buy, and whereby ROBERT MILK, KENNETH JOHNSON, CURTIS /ACREE, and ROOSEVELT WARREN acted as agents of aid enites andor obtined mois fom a bank acoount inthe name of said entities; and/or (3) pursuant oa conspiracy to commit this erin, with the intent thatthe crime be committed; knowingly offered for filing with the Department of Motor 9 || Vehicles a “Lien Sale Affidavit” andlor a “Lien Claimants Certification” for a 2013 Ford Taurus, 10 ||beaing VIN 1FAHP2KT3DG136398, knowing ssid documents to be false, which docurents | 1 || genuine might be filed with the Department of Motor Vehicles under the laws ofthe State of Nevada; 2 All of which constitutes the crime of OFFERING FALSE INSTRUMENT FOR FILING OR] 13 |] RECORD, a eategory “C” felony in violation of NRS 239.330. COUNTS tf OFFERING F) 1s 16 Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS ACRE, and ROOSEVELT] ‘Category "C Felony = NRS 239.330 Eat By Attrmey General Oise SSE Wang Ste 00 17 || WARREN, in the County of Clark, State of Nevada, either by virtue of their own actions or by the 18 || actions of their agents or employees, without lawful authority, knowingly procured or offered a false 19 |] instrument to be filed, to wit: 20 (On or about December 4, 2014, Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS, 21 || ACREE, and ROOSEVELT WARREN, without lawful authority, withthe Defendants being criminally 22 |[liable under one or more of the following principles of criminal liability, to-wit: (1) by diretly 23 || committing this crime; and/or (2) by aiding or abetting in the commission ofthis crime, with the intent 24 |] that this crime be committed, by providing counsel and/or encouragement and by entering into «course 25 || of conduet whereby ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, and ROOSSVELT| 26 || WARREN operated Tow Guys, Inc. andlor State Wide Towing and/or NV Ranch Ine. and/or NVT 27 || Storage and/or ASAP Towing and/or Roosevelt Cash for Cars Inc. andlor Towing Jamison Ine. andor 2g || Aquarius Towing and/or Great Buy, and whereby ROBERT MILK, KENNETH JOHNSON, CURTIS|Arse Genera fc /ACREE, and ROOSEVELT WARREN acted as agents of sid entities and/or obtained monies from a ‘bank account inthe name of said entities; and/or (3) pursuant to a conspiracy to commit this eime, with the intent thatthe crime be committed; knowingly offered for filing with the Department of Motor Vehicles a “Lien Sale Affidavit" and/or @ “Lien Claimants Certification” for a 2014 Kia Sorento, beating VIN SXYKT3A6XEGS24990, knowing said documents to be false, which documents if| genuine might be fled withthe Department of Motor Vehicles under the laws ofthe 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, counr7 OFFERING FALSE INSTRI )R FILING OR RECORD. ‘Category °C? Felony = NRS 239.330 Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, and ROOSEVELT ]WARREN, inthe County of Cink, State of Nevada, either by virtue of thee own ston or by the actions ofthis agents or employees, without lawful autor, knowingly procured or ofered a false instrument tbe filed, wit (On or about March 12, 2014, Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS | ACRE, and ROOSEVELT WARREN, without lawful autor, withthe Defendants being rininally liable under one oF more of the following principles of criminal lisbility, to-wit (1) by dre commiting this crime; andlor (2)by aiding or abeting in the commission ofthis evime, withthe itnt| that this crime be committed, by roving counsel andlor encouragement and by entering int a couse of conduct whereby ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, and ROOSEVELT| WARREN operated Tow Guys, Ine. andlor State Wide Towing andlor NV Reach Ine. andor NVT| Storage and/or ASAP Towing ani/or Roosevelt Cash for Ca Ine. andor Towing Jamison In, andor Aquarius Towing andlor Great Bay, and whereby ROBERT MILK, KENNETH JOHNSON, CURTIS| JACREE, and ROOSEVELT WARREN acted as agents of sid entities andor obtained monies fom a bank account inthe name of sid ets; andlor (3) pursuant «conspiracy to commit his crime, with the intent thatthe crime be committed; knowingly offered for filing with the Depatment of Motor Vehicles a “Lien Sale Affidavit” andlor a “Lien Claimant's Crificaton” fr 2007 Dodge Charger bearing VIN 2B3LAS3H37H783225, knowing said documeats tobe false, which document if genuine|might be filed with the Department of Motor Vehicles under the laws ofthe State of Nevada, All of which constitutes the erime of OFFERING FALSE INSTRUMENT FOR FILING OR, RECORD, a category “C” felony in violation of NRS 239.330 coUNTS OFFERING FALSE INSTRUMENT FOR FILING OR RECORD. Category *C* Felony = NRS 239350 Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, end ROOSEVELT WARREN, inthe County of Clark, State of Nevada, ether by virwe oftheir own actos or by the actions oftheir agents or employees, without lf authority, knowingly procured or cfeed false instrument o be ed, to wit (On or sbout July 31, 2013, Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS ACRE, and ROOSEVELT WARREN, without awful aubory, with the Defendants beng minal liable under one or more of the following principles of criminal ibility, toot (1) by dieuly commiting this exime; and/or (2) by ang or abeting inthe commission of his crime, wth the intent that tis rime be commited, by providing counsel andlor ennuragement and by entering into a couse of conduct whereby ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, and ROOSEVELT] | WARREN operated Tow Guys, Inc. andor State Wide Towing and/or NV Ranch In. andor NVT Storage andor ASAP Towing and/or Roosevelt Cash for Cars Tne. andlor Towing Jaisi fe andor Aqusius Towing andor Great Buy, and whereby ROBERT MILK, KENNETH JOHNSON, CURTIS| /ACREE, and ROOSEVELT WARREN aces agents of sid ents andlor obsined moses fom a bank secount in the name of sid entities; and/or (3) pursuan! oa conspiracy to commits rim, with the intent thatthe crime be commited; knowingly offered for filing with the Deparment of Motor en Claiman's Certfeation” for 2006 Mercedes C4, Vehides a “Lien Sale Affdevit” andlor a earisg, VIN WDDDITSX76A0S1372, knowing sid documents to be fise, whch document if genuine might be fled with the Depatnent of Motor Vehicles under the laws of the State of Neva; All of which constitutes the crime of OFFERING FALSE INSTRUMENT FOR FILING OR| RECORD, a category "C” felony in violation of NRS 239330. O aAttorney Generals Office STN counrs OFFERING FALSE INSTRUMENT FOR FILING OR RECORD. ‘Category “C” Felony ~ NRS 239.330 Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, and ROOSEVELT WARREN, in the County of Clark, State of Nevada, either by vitue oftheir own actions or by the actions oftheir agents or employees, witout lawful auoity, knowingly procured or offre fle instrument tobe ido wit (On or shout July 23, 2014, Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS| J ACRE, and ROOSEVELT WARREN, without awful aahorty, with the Defendants being iminally tisble under one or more of the following principles of cximiellisblity, to-wit (1) by directly commiting this crime; andlor (2) by aiding abetting inthe commission ofthis eime, withthe inet] that this rime be committed, by providing counsel and/or encouragement and by entering into a course of conduct whereby ROBERT MILK, KENNETH JOHNSON, CURTIS ACRE, and ROOSEVELT] WARREN operated Tow Guys, Ic. andlor State Wie Towing andor NV Ranch Inc, andlor NVT Storage andlor ASAP Towing andor Roosevelt Cash for Cas Inc. andlor Towing Jamison Ie andor Aquarius Towing and/or Great Buy, and whereby ROBERT MILK, KENNETH JOHNSON, CURTIS| ACRE, and ROOSEVELT WARREN ace as agents of aid entities and/or obtained monies rom a bank account inthe name of sid entities, andor (3 prsun! oa conspiracy to commit this xine, with the intent thatthe crime be commited; knowingly offerd for fling withthe Department of Motor Vehicles “Lien Sale Affidavit” andr a “Lien Claiman's Certification” for a 1997 Honda Givi, pearing VIN 2HGESS64XVHS52994, owing sid document tbe fle, which documents if genuine night be filed with the Department of Motor Vehicles under the aws ofthe Sate of Nevada {All of which consites the crime of OFFERING FALSE INSTRUMENT FOR FILING OR, RECORD, a category “felony in volation of NRS 259.30, ‘couNr 10 ING MONEY OR PRO! § SES ‘CATEGORY “B?” felony -NRS 205.380 Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, and ROOSEVELT WARREN, inthe County of Cla, State of Nevads, either by vue of ther own etos or by the tions oftheir agents or employees, without lawful authority, knowingly, by false pretense, obtainedEatin Bi Aton Geert Of ase weogen 0 u n B “ 15 6 ” 18 1» 2 2 2 4 25 a” 28 fiom any other person any money, goods, wares, chatels, or other valuable thing, withthe intent to cheat ordfiad the eer person, andthe vale of sid thing was $680 o more, to wit On oF shout November 22, 2013, Defendants ROBERT MILK, KENNETH JOHNSON, JCURTIS ACREE, and ROOSEVELT WARREN, without lawful authority, withthe Defendants being iy, tot: (1) by criminaly liable under one or more of the following principles of criminal i directly sommiting this exime; andlor (2) by sting or abeting inthe commission of this xe, with the intert that his crime be commited, by providing counsel andor encouragement and by etering into a courte of conduct wherchy ROBERT MILK, KENNETH JOHNSON, CURTIS ACRE, and ROOSEVELT WARREN operated Tow Guys, Inc andor Sate Wide Towing and/or NV Ranch In. andlor NVT Storage and/or ASAP Towing snd/r Roosevelt Cash for Cars Ine andor Towing Jamison Inc. andor Aquaria Towing andlor Great Buy, and whereby ROBERT MILK, KENNETH JOHNSON, CURTIS ACRE, and ROOSEVELT WARREN acted as agents of suid eites andor obtained monies fom a bank acount inthe name of sid ens; andlor (3) pursuant oa conspiracy to commit his crime, with the intent that the crime be commit; knowingly and designed offered fo fling with the Deparment of Motor Vehicles a “Lien Stle Afdovit™ andor a “Lien Caiman’ Corttinion” for a 2005 Ponte Aztec, bearing VIN. 3GTDAOSEOSSS05S62, which document isrepreseted that Defendants andor thei agents or employees ad sent required notice to Loan Max Tie Loms, thereby obtaining security interest in sid vehicle by fs pretense, with the vale of si 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. cOUNT IL OBTAINING MONEY OR PROPERTY UNDER FALSE PRETENSES ‘CATEGORY *B” felony -NRS 205.390 Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, and ROOSEVELT WARREN, inthe County of Cla, Stte of Neva, either by virtue of thei ov actions of by the action of heir agents or employes, without afl authority, knowingly, by false pretense, bined fom any other person any mone, goods, wares, cates, or other valuable thing, withthe intent to cheat or defraud the oer person, and the vale of si thing was $650 or moro Wit:10 n 18 19 2 2 2 28 26 2 8 (Om or ahout September 17, 2013, Defendants ROBERT MILK, KENNETH JOHNSON, JCURTIS ACRE, and ROOSEVELT WARREN, without lawful authority, withthe Defendants being] criminally able under one or more of the following principles of criminal ibity, to-wit (1) by| rectly commiting this crime; andlor (2) by aiding or sbeting in the commision ofthis rime, with the intent that this rime be commited, by providing cousel andlor encouragement and by entering into couse of conduct wherchy ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, and ROOSEVELT WARREN operated Tow Guys, Ine andor State Wide Towing andlor NV Ranch Ine andlor NVT Storage andlor ASAP Towing andor Roosevelt Cath for Cats ne. andor Towing Jamison Ine, andlor Aquarius Towing andlor Great Buy, and whereby ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, and ROOSEVELT WARREN acted as agents of sid entities andor tained monies fom a bank acount inthe name of sid ete; anor (3) pursuant a conspiracy to cominit hs crime, with the intent tat the exime be commited; knowingly and designelyofee for fling withthe Deparment of Motor Vehicles “Lien Sale Afidavit™ andor a “Lien Claman’ ]cericaton” for a 2006 Pontiac Tomeat, bearing VIN 2CKDL63F166096533, which documents misrepresented that Defendants andor their agents or employees had Seat required notice t Cama Business Services, thereby obtaining a security intrest in aid vehicle by false pretense, with the value of sid vehicle andor sort interest being 650 or more; [All of which constitutes the crime of OBTAINING MONEY OR PROPERTY UNDER FALSE PRETENSES, a category “B” felony ilation of NRS 205.380. COUNT 2 OBTAINING )R PROPERTY UNDER FALSE PRETENSES ‘CATEGORY “B” felony - NRS 205.380 Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS ACRE, and ROOSEVELT WARREN, in the County of Cla, State of Nevada, ether by vine oftheir own ston or by the actions oftheir agents or employes, witout lawful authority, knowingly, by fle pretense, ebsne ftom any other person any money, good, wares, chaltls,orotber valuable thing, with the intent to chest or defraud the other person, andthe vluc of said thing was $660 or more to wit (On or about ily 25, 2014, Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS | ACREE, and ROOSEVELT WARREN, without lawful abort, with the Defendant being criminally | aeAcorn Gnas Ot liable under one or more of the following principles of criminal liability, to-wit: (1) by diretly| committing this crime; andor (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 ito a course of conduct whereby ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, and ROOSEVELT WARREN operated Tow Guys, Inc, and/or State Wide Towing and/or NV Ranch Inc. and/or NVT| Storage and/or ASAP Towing andlor Roosevelt Cash for Cas Inc. and/or Towing Jamison Ine. and/or| Aquarius Towing and/or Great Buy, and whereby ROBERT MILK, KENNETH JOHNSON, CURTIS, JACREE, and ROOSEVELT WARREN acted as agents of ssid entities andor obtained monies from a| bank account in the name of said entities; and/or (3) pursuant to a conspiracy to commit this rime, with the intent that the crime be committed; knowingly and designedly offered for filing with the| [Department of Motor Vehicles @ “Lien Sale Affidavit” andor a “Lien Claimant's Cetifistion” for a 2001 Lincoln LS, hearing VIN 1LNHMS7A7IY617673, which documents misrepresented that Defendants andlor their agents or employees had sent required notice to Nevada Title and Payday| Loans, thereby obtaining a security interest in said vehicle by false pretense, with the value of sui| 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 i OBTAINING MONEY ‘CATEGORY “B” felony - NRS 205.380 Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, and ROOSEVELT) WARREN, in the 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, by fuse pretense, obtained from any other person any money, goods, wares, chattels, o other valuable thing, with te intent to lca or dfiaud the other person, and the valu of suid thing was $650 or more, to wit (On or about August 9, 2014, Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS: [ACREE, and ROOSEVELT WARREN, without lawful authority, with the Defendants being criminally liable under one or more of the following principles of criminal libiity, to-wit: (1) by direty| committing this exime; and/or (2) by aiding or abetting inthe commission ofthis crime, withthe intent “2rey Goats Otee tha this crime be committed, by providing counsel and/or encouragement and by eatering into a course of conduct witereby ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, and ROOSEVELT WARREN operated Tow Guys, Inc. and/or State Wide Towing and/or NV Ranch Inc. andlor NVT Storage and/or ASAP Towing and/or Roosevelt Cash for Cars Inc. and/or Towing Jamison In. and/or Aquarius Towing and/or Great Buy, and whereby ROBERT MILK, KENNETH JOHNSON, CURTIS ‘ACRE, and ROOSEVELT WARREN acted as agents of sid entities and/or obtained monies from a banc account in the name of ssid entities; and/or (3) pursuant to a conspiracy to commit this eime, with the intent that the crime be committed; Knowingly and designedly offered for fling with the| Department of Motor Vehicles a “Lien Sale Affidavit” andior a “Lien Claimant's Certification” for a 200) Cadillac Deville, bearing VIN 1G6KDS4Y4YU174283, which documents misrepresented that Deféndants andlor their agents or employees had sent required notice to Nevads Title and Payday | Loais, thereby obtaining a security interest in said vehicle by false pretense, withthe vale of said vehicle andor 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. COUNT 14 OBTAINING MONEY OR PROPERTY UNDER FALSE PRETENSES. ‘CATEGORY “B” felony - NRS 205.380 Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS ACRE, and ROOSEVELT WARREN, inthe County of Clark, State of Nevada, either by vite oftheir own actions or by the actins of ther agents or exployes, without lawful authority, knowingly, by false pretense, obtained fiom any other person any money, goods, wares, chattel, o other valuable thing, with th inet to cheat or defraud the ther person, andthe vac of si thing was $650 or mor, to wt (On or about May 27, 2014, Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS| J ACREE, and ROOSEVELT WARREN, without lawful authority, with he Defendants being ciminaly table under one or more of the following principles of ciminallabiliy, to-wit: (1) by direc committing this crime; andor (2) by aiding or abetting in the conumission of this rine, wih the intent that his crime be committed, by providing counsel andor excouragerent and by eting inf a course of conduct whereby ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, and ROOSEVELT|Atoney Genes Ofer SSE ou S00 WARREN operated Tow Guys, Ine. andor State Wide Towing andr NV Ranch Inc. andlor NVT Storage andlor ASAP Towing andlor Roosevelt Cash for Cas Inc. andlor Towing Jamison Ine. andor Aquarius Towing and/or Great Buy, and whereby ROBERT MILK, KENNETH JOHNSON, CURTIS) ACRE, and ROOSEVELT WARREN acted as agents of identities andor obtsned mone from a bank account inthe name of sid entities; andlor (3) pusuan! 0 a conspiracy to commit this rime, wth the intent that the cxine be committed; knowingly and designaly offered for filing wth the Department of Motor Vehicles a “Lien Sale Affidavit” andlor a “Lien Claimant's Ceticton” fora 2013 Ford Taurss, bearing VIN 1FAHP2KT3DG136398, which documents misrepreseted that Defendants andor thet agents or employees had sent requted notice to Carey MeGil, thereby obtaining a security interest in sid vehicle by false pretense, withthe value of suid vehicle and/or security intrest being S€S0 oF more; All of which conttates the crime of OBTAINING MONEY OR PROPERTY UNDER FALSE PRETENSES, a catogory “B” felony in violation of NRS 205.380. OBTAINING MONEY OR PROPERTY UNDER FALSE PRETENSES "ATEGORY “B” felony - NRS 205.380 Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, and ROOSEVELT] WARREN, in the Couny of Cla, State of Nevada citer by vrtwe of their own ations or by the actions oftheir agents o: employees, without lawl authority, knowingly, by false pretense, obtained fiom ay other person any money, goods, wares, chats, or other valuable thing, withthe inet to cheat or deftud the othe: person and the value of ai thing was $650 o mor, to wit nor about Decenber 4, 2014, Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS ACRE, and ROOSEVELT WARREN, without lwfl authority, with he Defendant being emily | liable under one or mote of the following principles of eximinal ability, to-wit: (1) by deal commiting this cime; andlor 2) by siding o abeting in the commission of this rime, wth the intent that his crime be commited, by providing counsel andor excnuragement and by entering into a course of conduct whereby ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, and ROOSEVELT WARREN operated Tow Guys, In. and/or State Wide Towing andor NV Ranch Inc. andor NVT Storage and/or ASAP Towing andor Roosevelt Cash for Cars Ine. andlor Towing Jamison Ine. andor oeES By Ataraey Genera Oe SSE Wang Suesic0 2 B “4 15 6 1” 18 9 20 a1 * 2s 26 2 28 Aquarius Towing andlor Great Buy, and whereby ROBERT MILK, KENNETH JOHNSON, CURTIS, | ACREE, and ROOSEVELT WARREN acted as agent of si ents andor obtained monis fom a] bank accoun:in the name of aid ents; andlor (3) pursuant oa conspirecy to commit this rim, wth tne intent hat the crime be committe; knowingly and designedly offered for filing with the Department of Motor Vehicles a “Lien Sale Affidavit” andlor a “Lien Claimants Cetfcaton” for a 2014 Kin Sorento, bearing VIN’ SXYKT3AGXEGS24990, which documents misepescted. that Defendants andr their agents or employees had sent requir notice to im Mach Kia andlor EAN Holding LLC, thereby obtaining security interest in said vehicle by false pete, withthe vale of| sid veicle andor security interest being $650 or more; Allo which constitutes the crime of OBTAINING MONEY OR PROPERTY UNDER FALSE| PRETENSES, a category “B” felony in violation of NRS 205.380, COUNT 16 OBTAINING MONEY OR PROPERTY UNDER FALSE PRETENSES ‘CATEGORY “B” felony -NRS 205.380, Deferdants ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE. and ROOSEVELT! |WARREN, inthe County of Cla, State of Nevad, either by vite oftheir ovn actions or by the action oftheir agents or employees, without lawful authority, knowingly, by fle pretess,obsined from any oter person any money, goods, wares, chattels, or other valuable thing, with the intent o cheat or defiaud the other person, and the value of sai thing was $650 or mor, to wit (On or sbout March 12, 2014, Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS /ACREE, and ROOSEVELT WARREN, without lavful autor, with the Defendant being criminal lable under one or more of the following principles of eiina ibility, to-wit (1) by diet commiting this rime; andor (2) by sing oF sbeting inthe commission ofthis rime, wth th inet that this crime be commited, by providing couse andlor envuragement and by entering into couse of conduct whereby ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, and ROOSEVELT JWARREN operated Tow Guy, Ine andlor Stte Wide Towing andlor NV Ransh Ie. andlor NYT} Storage ander ASAP Towing andor Roosevelt Cash for Cars Tne. andlor Towing Jamison fe. enor Aquarius Towing and/or Great Buy and whereby ROBERT MILK, KENNETH JOHNSON, CURTIS |ACREE, and ROOSEVELT WARREN acted as agents of sil ents andor obtined monies from a “1s:bank account in the name of said entities; and/or (3) pursuant toa conspiracy to commit this crime, with the intect that the crime be committed; knowingly and designedly offered for fling with the Department of Motor Vehicles a “Lien Sale Affidavit” andor a “Lien Clsimant’s Certification for a 2007 Dodge Charger, bearing VIN 2B3LAS3H37H783525, which documents misrepresented thet Defendants andor their agents or employees had sent required notice to On Call Cash, thereby obiaining a security interest in suid vehicle by false pretense, withthe value of suid vebicle andicr security interest being $650 or more; [All of which constitutes the rime of OBTAINING MONEY OR PROPERTY UNDER FALSE| PRETENSES, a category “B” felony in violation of NRS 205.380. u OBTAINING :TY UNDER FALS! ‘CATEGORY “B” felony - NRS 205.380 Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS ACRE, and ROOSEVEL"| WARREN, in the County of Clark, State of Neva, ether by virwe oftheir own ations or by he action oftheir agents or employees, without lawful authority, knowingly, by false pretense, obtainel fom any other person any money, goods, wares, chatel,o ther valuable thin, with he inten to cheat or defaud the other person, andthe value of suiting was 8650 or moe, wit On or about July 31, 2013, Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS /ACREE, and ROOSEVELT WARREN, without lawl authori, withthe Defendants Beng cimially lable index one or more of the fllowing principles of criminal Habit, toot (1) hy drat commiting this crime; and/or (2) by ang orabetng inthe commision ofthis crime, with the inte that this crime be commited, by providing counsel andlor encouragement and by entering ino couse of conduct whereby ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, and ROOSEVELT ]WARREN operated Tow Guys, Ine. andor State Wide Towing andle NV Ranch Inc. andlor NV Storage andlor ASAP Towing and/or Roosevelt Cash for Cas Ine, and/or Towing Jamison Ie. and: Aquarits Towing andor Great Buy, and whereby ROBERT MILK, KENNETH JOHNSON, CURTIS] ACRE, and ROOSEVELT WARREN acted as agents of sid entes andlor obtained monies from bank account in the name of sid ents; andlor (3) pursuant oa conspiracy to commit this rime, wth the intent that the crime be committed; knowingly and designedly offered for filing with the 16.Department of Motor Vehicles a “Lien Sale Affidavit” ander a “Lien Claimant's Certifatin’” for a 2006 Mercedes C4, bearing VIN WDDDITSX76A0S1372, which documents misreprescited tht Defendants andor their agents or employees had sent rered notice to Statewide Auto Servic, thereby odtaining a security interest in sid veicl by fe pretense, withthe valve of sid vehicle and/or security interest being $050 or more; All of which constitutes the eine of OBTAINING MONEY OR PROPERTY UNDER FALSE| PRETENSES, a category “B” felony in violation of NRS 205.380. COUNT 18 OBTAINING MONEY OR PR( N PRETENSES ‘CATEGORY “B" felony - NRS 205.380 Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, and ROOSEVELT] WARREN, in the County of Clark, State of Nevada, either by virtue of their own actions o by the actions oftheir agents or employees, without lawful authority, knowingly, by flse pretense, cbtained| fom any other person any money, goods, wares, chattels, or other valuable thing, with the intent to cheat or defraud the other person, andthe value of said thing was $650 or more, to wit: On or about July 23, 2014, Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS| ACRE, and ROOSEVELT WARREN, without lawl authority, with the Defendants being criminally Fable under one or more of the following principles of criminal liability, to-wit: (1) by direty| committing this crime; andor (2) by aiding or abetting inthe commission of tis crime, with the intent that this crime be committed, by providing counse! and/or encouragement and by entering nt « cours| lof conduct whereby ROBERT MILK, KENNETH JOHNSON, CURTIS ACRE, and ROOSVELT| WARREN operated Tow Guys, Inc. and/or State Wide Towing and/or NV Ranch Ine. andor NVT| Storage and/or ASAP Towing and/or Roosevelt Cash for Cars Inc. and/or Towing Jamison Ine and/or Aquarius Towing and/or Great Buy, and whereby ROBERT MILK, KENNETH JOHNSON, CURTIS |ACREE, and ROOSEVELT WARREN acted as agents of sai entities andor obtained monies from a bank account in the name of said entities; andor (3) pursuant to a conspiracy to commit his crime, with the intent that the crime be committed; knowingly and designedly offered for filing with th| Department of Motor Vehicles a “Lien Sale Affidavit” andlor a “Lien Claimant's Certification” for a 1997 Honda Civic, bearing VIN 2HGEI864XVHS52396, which documents misrepresented that “7Arey Geert fe SSE Weegee 0 Estee Bis 10 u 2 B 4 15 16 7 18 19 20 2 2 23 24 as 2 28 Defendants andor ther agents or employees had sent required ane to Tile Max of Neva, thereby obtaining a security interest in sid vehicle by false pretense, with the value of suid vehi andor security intrest being $650 or more; All of which costintes the crime of OBTAINING MONEY OR PROPERTY UNDER FALSE, PRETENSES, a category “B"” felony in violation of NRS 205 380, COUNT 19 ‘OF STOLE? LE ‘CATEGORY “B” felony - NRS 205.273 Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, and ROOSEVELT| | WARREN, in the County of Clark, State of Nevada, either by virtue of ther own actions or by the| actions oftheir agents or employees, without lawful authority, knowingly, by flse pretense, obtained from any other person any money, goods, wares, chattels, or other valuable thing, with the intent to cheat or deftaud the other person, andthe value of sai thing was $650 or more, to wit: (On or about January 21, 2015, Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS ACRE, and ROOSEVELT WARREN, 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 this crime; andor (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 course of conduct whereby ROBERT MILK, KENNETH JOHNSON, CURTIS ACREF, and ROOSEVELT] WARREN operated Tow Guys, Inc. andlor State Wide Towing and/or NV Ranch Inc, and/or NVT| ‘Storage andlor ASAP Towing and/or Roosevelt Cash for Cars Ine. and/or Towing Jamison inc. and/or Aquarius Towing and/or Great Buy, and whereby ROBERT MILK, KENNETH JOHNSON, CURTIS. [ACREE, and ROOSEVELT WARREN acted as agents of sid entities and/or obtained monies from a bank account in the name of said entities; and/or (3) pursuant toa conspiracy to commit tis crime, with| the intent that the crime be committed; knowingly had in their possesion a motor vehicle which they ew or had reason to believe had bean stolen from JIM MARSH KIA, toi 2014 Kia Sorento bearing VIN SXYKT3A6XEGS24990; [All of which constitutes the crime of OBTAINING MONEY OR PROPERTY UNDER FALSE PRETENSES, a category “B” felony in voltion of NRS 205380. 18.tres Gees Oice SSE Wan Sat u 2 B 4 1s 16 7 18 9 2 a 4 25 26 u 28 count 20 Boss} SUBSTANCE WITH INTENT TO SELL ‘CATEGORY “D” felony - NRS 453.337 On or shout January 21, 2015, Defendant ROBERT MILK, in the County of Clark, State of| Nevada, did knowingly possess, either actually or constrcively, without lawful authority, for the purpose of sale, a controlled substance, to-wit: morphine; All of which constitutes the crime of POSSESSION OF CONTROLLED SUBSTANCE WITH INTENT TO SELL, a category “D” felony in violation of NRS 453.337 count 21 POSSESSION OF Doct ENTIFVING INFO} NTO ESTABLISH FALSE STATUS OR IDENTITY ‘CATEGORY “E? felony - NRS 205.465 On or about January 21, 2015, Defendant ROBERT MILK, in the County of Cla, State of| Nevada, did knowingly possess, either actually or constructively, a document or personal identifying Nevada 1D] information for the purpose of establishing a fale status or deity for himself, to-wit card inthe name of Devid Miler, All of which constitutes the crime of POSSESSION OF DOCUMENT OR FERSONAL| IDENTIFYING INFORMATION TO ESTABLISH FALSE STATUS OR IDENTITY, a catepry “E" felony in violation of NRS 205.465, count 22 POSSESSION OF DOCUMENT OR \TIONTO ESTABI sE STATUS OR IDENTITY "ATEGORY “E? felony - a (On or about January 21, 2015, Defendant ROBERT MILK, inthe County of Cla, State of] Nevaie, did knowingly possess, cither actually or constructively, a document or personal identifing information forthe purpose of establishing «false status or identity for himself, to-wit: a Nevada driver's eens in the name of Cuts Delray; [AI of which consites the ctime of POSSESSION OF DOCUMENT OR PERSONAL IDENTIFYING INFORMATION TO ESTABLISH FALSE STATUS OR IDENTITY, a catepy“E" elonyin violation of NR 205 465. a a 19.Cas Nepa NY a8 Arne Genera Of COUNT 23, POSSESSION OF DOCI s ENTH ATI ESTABLISH FALSE STATUS OR IDENTITY. CATEGORY “B” felony -NRS 205.465 (nor about January 21, 2015, Defendant ROBERT. MILK, in the Couty of Clik, State of Nevada, did knowingly posses, ether actully or constructively, a documento personal ideatiffing information forthe purpose of establishing a false status or identity fr himself, to-wit: a Nevada driver's cease inthe name of Robert Miler Alf which constitutes the cimme of POSSESSION OF DOCUMENT OR PERSONAL, IDENTIFYING INFORMATION TO ESTABLISH FALSE STATUS OR IDENTITY, a category “E" felony in violation of NRS 205 465. count 2 POSSESSION OF DOCUM ENTIFYING INFORMATION IH FALSE STATUS ‘CATEGORY * felony - NRS 205.465 On or about January 21, 2015, Defendant ROBERT MILK, in the Couny of Cla, State of Nevada, did knowingly possess, either actully or constructively, a document or prsonlientifhing information ‘or the purpose of establishing a false statu or identity for himself, to-wit « Nevada auiver’s iene in the name of Edward Milk; |All of which constintes the crime of POSSESSION OF DOCUMENT OR PERSONAL| IDENTIFYING INFORMATION TO ESTABLISH FALSE STATUS OR IDENTITY, a category “E” felony in violation of NRS 205.465. EFERING FALSE INSTRUMENT FOR FILING OR RECORD ‘Category “C” Felony - NRS 239.330 Defendant ROBERT MILK, in the County of Clark, State of Nevada, ether by vitwe of his owa| actions or bythe actions of his agents or employes, without lawl authority, km>wingly procured or offered afl instrument to be od to wit (On orabout October 7, 2014, Defendant ROBERT MILK knowingly offered for ing wih he Nevada Secretary of State, Articles of Incorporation for Great Buy Inc, which document sted David Miller as Registered Agent, knowing std document tobe fle, which document if gontine might be filed withthe Secretary of Stato under the laws ofthe State of NevadaAttorney Genera Office 0 u 2 3 “4 15 16 7 18 19 20 a 2 23 25 26 2 28 All of which constitutes the crime of OFFERING FALSE INSTRUMENT FOR FILING OR] RECORD, a category “C” felony in violation of NRS 239,330 PERJURY Category “D® Felony - NRS 199.145 Defendant ROBERT MILK, in the County of Clk, Ste of Nevada, either by virtue ofhis own) actions or by the ations of his agents or employees, without awl authority, willl made a false statement in a declaration made under penalty of perjury, wit (On or about October 7, 2014, Defendant ROBERT MILK willy offered for fling withthe Nevada Secretary of Stats, Articles of Incorporation for Great Buy Inc, which document listed David Miller as Registered Agen, knowing that statement to be fle and that David Miler isnt rel person, which statement was material to the filing in question; * felony in violation of NRS| All of which constitutes the crime of PERJURY, a estegory “ 199.148. ce COUNT 27 MULTIPLE TRANSACTIONS INVOLVING FRAUD OR DECEIT IN COURSE OF ‘ENTERPRISE OR OCCUPATION RPRISE OR OCCUPATION ‘Category “B” Felony -NRS 205.377 Between July 2013 and January 2015, Defendants ROBERT MILK, KENNETH JOHNSON, |CURTIS ACRE, and ROOSEVELT WARREN, without lawful authority, withthe Defendants being| criminally liable under one or more of the following principles of eximinal Liability, to-wit (1) by’ rectly committing this crime; and/or (2) by aiding or abeting inthe 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 ROBERT MILK, KENNETH JOHNSON, CURTIS ACRE, and| ROOSEVELT WARREN operated Tow Guys, Inc. and/or State Wide Towing and/or NV Ranch Inc. andlor NVT Storage and/or ASAP Towing and/or Roosevelt Cash for Cas Inc. and/or Towing Jamison| Tne, and/or Aquarius Towing and/or Great Buy, and whereby ROBERT MILK, KENNETH JOHNSON, CURTIS ACRE, and ROOSEVELT WARREN acted as agents of said entities andor obtained monies from a bank account inthe name of said entities; andor (3) pursuant toa conspiracy to commit this crime, with the intent that the crime be committed [As set forth in Counts One (1) through Eighteen (18), incorporated by reference as though flly| 210 2 B 14 1s 6 ” 18 19 2 2 4 25 6 n 28 set forth herein, Defendants have committed multiple transactions invalving faud or decit in the couse of enterprise or occupation, in two or more transaction in which the purpose, results, methods ‘orcommission was the same or similar; each having a value of $650 or more. All of which constitutes the rime of MULTIPLE TRANSACTIONS INVOLVING FRAUD (OR DECEIT, a category “B” felony in violation of NRS 20877 COUNT 28 RACKETEERING Category “B” Felony - NRS 207.400, 207.360, 207390 Between July 2013 and January 2015, Defendants ROBERT MILK, KENNETH JOHNSON, | CURTIS ACRE, and ROOSEVELT WARREN, without awful authority, with the Defendants being| criminally Liable under one or more of the following principles of criminal ibility, to-wit (1) by’ ditecly committing this erime; and/or (2) by aiding or abeting in the cormission of this crime, with the intent that this crime be committed, by providing counsel and/or encouragement and by enterin| into a course of conduct whereby ROBERT MILK, KENNETH JOHNSON, CURTIS ACREF, and| ROOSEVELT WARREN operated Tow Guys, Inc. and/or State Wide Towing and/or NV Ranch Inc. and/or NVT Storage and/or ASAP Towing and/or Roosevelt Cash for Cas Inc, and/or Towing Jamison| lac, andlor Aquarius Towing and/or Great Buy, and whereby RO3ERT MILK, KENNETH | JOHNSON, CURTIS ACRE, and ROOSEVELT WARREN acted as agents of said entities andor bisined monies from a bank account inthe name of said entities; and/or (3) pursuant to a conspiracy to commit this crime, with the intent that the crime be committed; Defendants have engaged in at least two crimes related to racketesrng that have the same o| similar patter, intents, results, or methods of commission, or are otherwise interelted. Defendants ROBERT MILK, KENNETH JOHNSON, CURTIS ACREE, and ROOSEVELT WARREN were| [employed by or associated with Tow Guys, Ine. andlor State Wide Towing and/or NV Ranch In. andlor NVT Storage and/or ASAP Towing and/or Roosevelt Cash for Cars nc. and/or Towing Jamison Ine andlor Aquarius Towing andlor Great Buy, and while so employed or associated, conducted or patcipated, directly or indirectly, in the aflirs of said entities through racketeering activity, andor in racketeering activity through the affairs of said entities, as set forth in Counts Ten (10) through Eighteen (18) and in Count Twenty-Seven (27), incorporated by reference as though fully set forth 2_Attarney General's Office ESSER Bi herein. ‘As a result of said acts, Defendants unlawfully obtained or derived at last $2,000,000.00 from racketeering activity. All of which constitutes the crime of RACKETEERING, a eategory “B” fefony in violation of| NRS 205.377. “ DATED this_25“ day of October, 2016. ADAM PAUL LAXALT ‘Attomey By: id We Seaior Deputy Attorney General ENDORSEMENT: A TrueBill By: ‘County Grand Tary