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    Ny-Tran Complaint

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    The San Joaquin County District Attorney’s Office filed charges against Stockton Police Department Officer Ny Tran after an investigation into theft of an elder, forgery, grand theft, and fraudulent use of a credit card.

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    Ny-Tran Complaint

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    West Hub
    7K views5 pages
    The San Joaquin County District Attorney’s Office filed charges against Stockton Police Department Officer Ny Tran after an investigation into theft of an elder, forgery, grand theft, and fraudulent use of a credit card.

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    Ny-Tran complaint

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    The San Joaquin County District Attorney’s Office filed charges against Stockton Police Department Officer Ny Tran after an investigation into theft of an elder, forgery, grand theft, and fraudulent use of a credit card.

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    © All Rights Reserved
    Download as PDF, TXT or read online from Scribd
    Download as pdf or txt
    7K views5 pages

    Ny-Tran Complaint

    Uploaded by

    West Hub
    The San Joaquin County District Attorney’s Office filed charges against Stockton Police Department Officer Ny Tran after an investigation into theft of an elder, forgery, grand theft, and fraudulent use of a credit card.

    Copyright:

    © All Rights Reserved
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    of 5

    ELECTRONICALLY FILED

    Superior Court
    Case No: STK-CR-FE-2022-0011107
    Date: 11/10/2022
    1 TORI VERBER SALAZAR
    District Attorney, County of San Joaquin By: Rebecca Perez
    2 State Bar Number
    By: Sean Doering, SBN 289435
    3 Deputy District Attorney
    222 E. Weber Avenue, First Floor, Room 101,
    4 P.O. Box 990
    Stockton, California 95201
    5
    Telephone: (209) 468-2400
    6
    Attorneys for Plaintiff
    7

    8 SUPERIOR COURT OF THE STATE OF CALIFORNIA, COUNTY OF SAN JOAQUIN


    9 STOCKTON BRANCH
    10

    11 THE PEOPLE OF THE STATE OF CALIFORNIA, No. 077-0926505


    SAN JOAQUIN COUNTY
    12 Plaintiff, DISTRICT ATTORNEY'S OFFICE
    CASE
    13 vs. DA Case: 0929959

    14 NY TRAN, Complaint No: 202211100006

    15 Defendant(s). COMPLAINT

    16

    17 I, the undersigned, say, on information and belief, that in the County of SAN JOAQUIN, State
    18 of California:
    19

    20 COUNT 1: Code Section PC 368(D) THEFT FROM ELDER OR DEPENDENT ADULT


    21 EXCEEDING $950
    22 On or about July 14, 2022 through and including August 4, 2022 in the County of San Joaquin,
    23 California, NY TRAN did commit the crime of THEFT FROM ELDER OR DEPENDENT
    24 ADULT EXCEEDING $950, in violation of Section 368(d) of the Penal Code, a FELONY,
    25 who at the time and place last aforesaid, unlawfully committed theft, embezzlement, forgery,
    OR’D 11/14/2022 130 8

    26 fraud, and identity theft with respect to the property and personal identifying information of an
    27 elder and dependent adult, said property, moneys, labor, goods, and services taken and obtained
    28

    1
    1 having a value exceeding $950.00 ***TO WIT: $45,698.33, and knew and reasonably should

    2 have known that said person, Ken Urabe, was an elder and dependent adult.

    4 For a further and separate cause of complaint, being a different offense from but connected in

    5 its commission with the charge(s) above, complainant further complains and says:

    7 COUNT 2: Code Section PC 487(A) GRAND THEFT:MONEY/LABOR/PROPERTY

    8 On or about July 14, 2022 through and including August 4, 2022 in the County of San Joaquin,

    9 California, NY TRAN did commit the crime of GRAND

    10 THEFT:MONEY/LABOR/PROPERTY, in violation of Section 487(a) of the Penal Code, a

    11 FELONY, who at the time and place last aforesaid, did willfully and unlawfully take money

    12 and personal property of another of a value exceeding nine hundred fifty dollars ($950.00), to-

    13 wit: Ken Urabe CHECK TOTALLING $45,698.33.

    14

    15 For a further and separate cause of complaint, being a different offense from but connected in

    16 its commission with the charge(s) above, complainant further complains and says:

    17

    18 COUNT 3: Code Section PC 470(D) FORGERY

    19 On or about July 25, 2022 in the County of San Joaquin, California, NY TRAN did commit the

    20 crime of FORGERY, in violation of Section 470(d) of the Penal Code, a FELONY, who at the

    21 time and place last aforesaid did, with the intent to defraud, falsely make, alter, forge and

    22 counterfeit, utter, publish, pass and attempt and offer to pass, as true and genuine, to-wit:

    23 PERSONAL CHECK TOTALLING $42,500.00, knowing the same to be false, altered, forged

    24 and counterfeited.

    25

    26 For a further and separate cause of complaint, being a different offense from but connected in

    27 its commission with the charge(s) above, complainant further complains and says:

    28

    2
    1

    2 COUNT 4: Code Section PC 530.5(A) IDENTITY THEFT

    3 On or about July 14, 2022 through and including November 8, 2022 in the County of San

    4 Joaquin, California, NY TRAN did commit the crime of IDENTITY THEFT, in violation of

    5 Section 530.5(a) of the Penal Code, a FELONY, who at the time and place last aforesaid, did

    6 willfully and unlawfully obtain personal identifying information ***TO WIT: PERSONAL

    7 CHECKS, CREDIT CARD of Ken Urabe without authorization, and used that information for

    8 an unlawful purpose, including to obtain, or attempt to obtain, credit, goods, services, real

    9 property, or medical information without the consent of said victim.

    10

    11 For a further and separate cause of complaint, being a different offense from but connected in

    12 its commission with the charge(s) above, complainant further complains and says:

    13

    14 COUNT 5: Code Section PC 484G USE OF CREDIT CARD OBTAIN UNDER 484(E)

    15 OR FORCED CARD

    16 On or about July 14, 2022 through and including August 4, 2022 in the County of San Joaquin,

    17 California, NY TRAN did commit the crime of FRAUDULENT USE OF ACCESS CARD, in

    18 violation of Section 484g of the Penal Code, a FELONY, who at the time and place last

    19 aforesaid did willfully, unlawfully with intent to defraud, OBTAIN MONEY, GOODS,

    20 SERVICES AND ANYTHING ELSE OF VALUE BY REPRESENTING THAT HE/SHE

    21 WAS THE HOLDER OF AN ACCESS CARD WITHOUT THE CONSENT OF THE CARD

    22 HOLDER. It is further alleged that the value of all money, goods, services and other things of

    23 value obtained during the six consecutive month period ending AUGUST OF 2022

    24 TOTALLING $3,198.33.

    25

    26 For a further and separate cause of complaint, being a different offense from but connected in

    27 its commission with the charge(s) above, complainant further complains and says:

    28

    3
    1

    2 COUNT 6: Code Section PC 470(D) FORGERY

    3 On or about August 30, 2022 in the County of San Joaquin, California, NY TRAN did commit

    4 the crime of FORGERY, in violation of Section 470(d) of the Penal Code, a FELONY, who at

    5 the time and place last aforesaid did, with the intent to defraud, falsely make, alter, forge and

    6 counterfeit, utter, publish, pass and attempt and offer to pass, as true and genuine, to-wit:

    7 PERSONAL CHECK TOTALLING $60,000.00, knowing the same to be false, altered, forged

    8 and counterfeited.

    10 For a further and separate cause of complaint, being a different offense from but connected in

    11 its commission with the charge(s) above, complainant further complains and says:

    12

    13 COUNT 7: Code Section PC 470(D) FORGERY

    14 On or about August 30, 2022 in the County of San Joaquin, California, NY TRAN did commit

    15 the crime of FORGERY, in violation of Section 470(d) of the Penal Code, a FELONY, who at

    16 the time and place last aforesaid did, with the intent to defraud, falsely make, alter, forge and

    17 counterfeit, utter, publish, pass and attempt and offer to pass, as true and genuine, to-wit:

    18 PERSONAL CHECK TOTALLING $8,500.00, knowing the same to be false, altered, forged

    19 and counterfeited.

    20

    21 If the above-named defendant(s) is/are presently on probation in San Joaquin County, any

    22 evidence presented at a preliminary hearing in the instant case will be used not only as a basis

    23 for a holding order in this case but also as evidence of a violation of probation and, at any

    24 formal hearing on that violation of probation, the People will move the transcript of the

    25 preliminary hearing into evidence as a basis for the violation.

    26

    27

    28

    4
    1 Pursuant to Penal Code Section 1054.5(b), the People hereby informally request that the

    2 defendant and their attorney disclose to the People all information and materials described in

    3 Penal Code Section 1054.3.

    5 I declare under penalty of perjury that the foregoing is true and correct except for those things

    6 stated on information and belief and those I believe to be true.

    8 Executed on November 9, 2022, at Stockton, California.

    10
    SEAN DOERING
    11 Deputy District Attorney
    SD/cw
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