STANISLAUS COUNTY SUPERIOR COURT STATE OF CALIFORNIA ________________________________________ THE PEOPLE OF THE STATE OF CALIFORNIA, ) vs. ) ) ) TONY HUY HAVENS ) (DOB: 08-29-73) ) (AT LARGE) ) DEFENDANT(S) ) ) No. 1255669 ) _______________________________________)
State of California ) County of Stanislaus ) ss.
COMPLAINT -- CRIMINAL
DA 08-349
On January 13, 2009, GLENN GULLEY, DISTRICT ATTORNEY’S OFFICE, complains and alleges, upon information and belief, that said defendant(s) did commit the following crime(s) in the County of Stanislaus, State of California. COUNT I: On or about March 22, 2005, defendant(s) did commit a felony, GRAND THEFT, violation of Section 487(a) of the California Penal Code, in that the defendant(s) did willfully, unlawfully and feloniously take the property of another, to wit, ELBA L. LANDIN, of a value exceeding Four Hundred Dollars ($400.00). COUNT II: On or about and between June 5, 2007 to September 5, 2007, defendant(s) did commit a felony, GRAND THEFT, violation of Section 487(a) of the California Penal Code, in that the defendant(s) did willfully, unlawfully and feloniously take the property of another, to wit, KATHRYN ANN CONTI, of a value exceeding Four Hundred Dollars ($400.00). COUNT III: On or about and between February 6, 2008 to March 3, 2008, defendant(s) did commit a felony, GRAND THEFT, violation of Section 487(a) of the California Penal Code, in that the defendant(s) did willfully, unlawfully and feloniously take the property of another, to wit, MICKEY G. WHITAKER, of a value exceeding Four Hundred Dollars ($400.00). COUNT IV: On or about and between March 26, 2008 to May 16, 2008, defendant(s) did commit a felony, GRAND THEFT, violation of Section 487(a) of the California Penal Code, in that the defendant(s) did willfully, unlawfully and feloniously take the property of another, to wit, ANDRE KANDY, DDS, of a value exceeding Four Hundred Dollars ($400.00). COUNT V: On or about April 8, 2008, defendant(s) did commit a felony, GRAND THEFT, violation of Section 487(a) of the California Penal Code, in that the defendant(s) did willfully, unlawfully and feloniously take the property of another, to wit, RICHARD LANDRY, of a value exceeding Four Hundred Dollars ($400.00). COUNT VI: On or about June 3, 2008, defendant(s) did commit a felony, GRAND THEFT, violation of Section 487(a) of the California Penal Code, in that the defendant(s) did willfully, unlawfully and feloniously take the property of another, to wit, JULIUS POSTON, of a value exceeding Four Hundred Dollars ($400.00). ///
COUNT VII: On or about July 15, 2008, defendant(s) did commit a felony, GRAND THEFT, violation of Section 487(a) of the California Penal Code, in that the defendant(s) did willfully, unlawfully and feloniously take the property of another, to wit, NATHAN GLICK, of a value exceeding Four Hundred Dollars ($400.00). COUNT VIII: On or about July 15, 2008, defendant(s) did commit a felony, GRAND THEFT, violation of Section 487(a) of the California Penal Code, in that the defendant(s) did willfully, unlawfully and feloniously take the property of another, to wit, CHRISTINE ANN TOWNS, of a value exceeding Four Hundred Dollars ($400.00). COUNT IX: On or about September 19, 2008, defendant(s) did commit a felony, GRAND THEFT, violation of Section 487(a) of the California Penal Code, in that the defendant(s) did willfully, unlawfully and feloniously take the property of another, to wit, GLENN WILLIAMS, of a value exceeding Four Hundred Dollars ($400.00). COUNT X: On or about and between October 1, 2008 to December 31, 2008, defendant(s) did commit a felony, GRAND THEFT, violation of Section 487(a) of the California Penal Code, in that the defendant(s) did willfully, unlawfully and feloniously take the property of another, to wit, THOMAS NICOLAS LUX, of a value exceeding Four Hundred Dollars ($400.00). THE FOLLOWING ENHANCEMENT APPLIES TO COUNTS 2 - 10 ENHANCEMENT: At the time of the commission of the above offense, the defendant had been released on bail and/or own recognizance pending judgment becoming final on an earlier felony offenses, pursuant to Penal Code Section 12022.1, in the jurisdiction of the Superior Court, County of Stanislaus, State of California, Action No. 1223885. THE FOLLOWING SPECIAL ALLEGATION APPLIES TO COUNTS 1 - 10 SPECIAL ALLEGATION: It is further alleged pursuant to Penal Code Section 186.11(a)(2), that the defendant committed two or more related felonies, a material element of which is fraud, which involve a pattern of related felony conduct, and the pattern of related felony conduct involves the taking of more than Five Hundred Thousand Dollars ($500,000.00), to wit, Seventeen Million, Three Hundred, Ten Thousand Dollars ($17,310.000.00). ///
THE FOLLOWING ENHANCEMENT APPLIES TO COUNT 5 ONLY ENHANCEMENT: During the commission of the above offense, the defendant did intentionally take, damage and destroy property, in excess of $2,500,000.00, to wit, Eight Million Dollars ($8,000,000.00) in violation of §12022.6(a)(4) of the California Penal Code. THE FOLLOWING ENHANCEMENT APPLIES TO COUNT 7 ONLY ENHANCEMENT: During the commission of the above offense, the defendant did intentionally take, damage and destroy property, in excess of $2,500,000.00, to wit, Nine Million, Two Hundred Thousand Dollars ($9,200,000.00) in violation of §12022.6(a)(4) of the California Penal Code.
WRM/rs
All of which is contrary to law in such cases made and provided, and against the peace and dignity of the People of the State of California. Said Complaint therefore prays that a warrant be issued for the arrest of said defendant(s) and that said defendant(s) be dealt with according to law. I certify under penalty of perjury, at Modesto, California, that the foregoing is true and correct.
Dated: ______________________
_________________________________ Complainant