The Orange County District Attorney charges that in Orange County, California, the law was violated as follows:

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COUNTY OF ORANGE, CENTRAL JUSTICE CENTER FELONY COMPLAINT WARRANT No.10CF0125 OCDA 00017653 _______________________________________

THE PEOPLE OF THE STATE OF CALIFORNIA, ) ) Plaintiff, ) ) ) vs. ) ) CHRISTOPHER LEE DIENER 01/03/68 ) C4083941 ) AKA CHRISTOPHER LEE PIENEN ) CHRISTOPHER LEE DIGNER ) CHRISTOPHER DIENER ) STEFANO JOSEPH MARRERO 02/19/69 ) C5527563 ) TERRENCE LESEAN GREEN SR 07/28/66 ) A4007183 ) ) Defendant(s))

The Orange County District Attorney charges that in Orange County, California, the law was violated as follows:

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OVERT ACT 1

The defendants created one or more business entities to process loan modifications.

On March 3, 2008, defendant Green signed Articles of Organization for Home Relief Services, LLC. Defendant Marrero was also an executive of this company. Defendants later conducted business under the names US Loan Mod Processing, HRS Communications and the Diener Law Firm.

OVERT ACT 2

The defendants obtained operating funds and opened bank accounts.

On March 15, 2008, defendants Green and Marrero signed a promissory note from attorney Ronald Specter to borrow $150,000 as start up capital. Thereafter, bank accounts were opened by defendants at Orange County Business Bank (on 3/18/08) and US Bank.

OVERT ACT 3

The defendants advertised their services on the internet, radio and television both in and outside of California.

OVERT ACT 4

The defendants hired, "trained" and supervised a staff of employees to solicit customers and/or respond to customer requests for a loan modification

OVERT ACT 5

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OVERT ACT 6

The defendants had contracts prepared and distributed to customers for them to sign prior to rendering any services.

OVERT ACT 7

The defendants solicited their employees to act as cappers (as defined in Business and Profession Code section 6151), and directed them to solicit customers and procure business on behalf of defendant Diener, an attorney, a criminal violation under Business and Professions Code section 6152.

OVERT ACT 8

The defendants and their employees deliberately made false promises to entice customers to purchase their services. These material misrepresentations include telling potential customers one or more of the following, that:

(a) they could guarantee a loan modification

(b) they would be able to negotiate lower interest rates from lenders, including fixed rate loans of 4%

(c) they would be able to obtain reductions in the principal owed on the customer's mortgage

(d) that in many instances they would be able to have any second mortgage eliminated/forgiven

(e) they would be able to get any arrearages or late fees forgiven by the lender

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OVERT ACT 9

The defendants opened multiple credit card processing/servicing accounts to collect monies from their customers: UMS Banking (on 3/20/08), United Bank Card (by Diener on 12/18/08), Humboldt Merchant Services (on 12/18/08), Meritus (by Diener on 1/8/09) and Group ISO (by Diener on 1/20/09)

OVERT ACT 10

The defendants obtained "advance fees" from customers from across the United States in advance of rendering any services to them.

OVERT ACT 11

The defendants operated a "retail business" dealing directly with customers seeking loan modifications.

OVERT ACT 12

The defendants opened and operated a "wholesale business" and solicited real estate brokers and other professionals, promising to pay them referral fees for each customer referred, in effect soliciting these"wholesalers" to be cappers for defendant Diener. These entities included: The Mortgage Modification Network (Tustin, CA), National Mitigation Services (Corona, CA), EQI (Laguna Niguel, CA), National Mortgage Counseling Group (Irvine, CA) and American Help Center (Irvine, CA).

OVERT ACT 13

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OVERT ACT 14

On February 4, 2009, the California Dept of Real Estate filed an Order to Desist and Refrain against Home Relief Services, LLC, defendants Green and Marrero and others, none of whom were licensed as real estate brokers, for soliciting loan modification business and collecting advance fees. Thereafter, the defendants purportedly shut down Home Relief Services but continued to conduct business as usual but under the Diener Law Firm umbrella to avail themselves of the "lawyer" exemption then existing under California Civil Code section 2945.

OVERT ACT 15

On May 5, 2009, the Office of the Commissioner of Financial Regulation in Maryland issued a Cease & Desist Order against defendant Diener and Home Relief Services outlining numerous violations of Maryland law. Defendant Diener is not licensed to practice law in Maryland.

OVERT ACT 16

Between June and July 2009, the defendants received and/or responded to complaints forwarded from various state attorney general offices, to include: Indiana (6/10/09), Hew Hampshire (6/16/09), Arizona (7/9/09) and North Carolina

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COUNT 3: On or about June 12, 2008, in violation of Section 487 (a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of HECTOR A. of a value exceeding four hundred dollars ($400). To wit: $1,500.00.

COUNT 4: On or about June 20, 2009, in violation of Section 487 (a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of MICHAEL B. of a value exceeding four hundred dollars ($400). To wit: $1,500.00.

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COUNT 6: On or about December 11, 2008, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of CHRISTINE B. of a value exceeding four hundred dollars ($400). To wit: $6,000.00

COUNT 7: On or about August 14, 2008, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of MATTHEW B. of a value exceeding four hundred dollars ($400). To wit: $2,995.00.

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COUNT 9: On or about January 09, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of HECTOR C. of a value exceeding four hundred dollars ($400). To wit: $2,695.00

COUNT 10: On or about February 01, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of STEPHEN C. of a value exceeding four hundred dollars ($400). To wit: $6,000.00.

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COUNT 12: On or about May 01, 2009, in violation of Section 487 (a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of ASSI C. of a value exceeding four hundred dollars ($400). To wit: $4,000.00.

COUNT 13: On or about March 17, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of JOHN C. of a value exceeding four hundred dollars ($400). To wit: $2,500.00.

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COUNT 15: On or about January 27, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of KEMCU D. of a value exceeding four hundred dollars ($400). To wit: $4,444.00.

COUNT 16: On or about September 01, 2008, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of LUCIA D. of a value exceeding four hundred dollars ($400). To wit: $2,395.00.

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COUNT 18: On or about and between March 01, 2009 and April 30, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of DANIELLE H. of a value exceeding four hundred dollars ($400). To wit: $2,995.00

COUNT 19: On or about December 30, 2008, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of HELEN F. of a value exceeding four hundred dollars ($400). To wit: $2,495.00.

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COUNT 21: On or about June 20, 2008, in violation of Section 487 (a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of ZELDA J. of a value exceeding four hundred dollars ($400). To wit: $1,995.00.

COUNT 22: On or about September 15, 2008, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of DEBRA J. of a value exceeding four hundred dollars ($400). To wit: $1,500.00.

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COUNT 24: On or about August 01, 2008, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of MARGARITA L. of a value exceeding four hundred dollars ($400). To wit: $1,900.00.

COUNT 25: On or about November 24, 2008, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of PATRICIA L. of a value exceeding four hundred dollars ($400). To wit: $1,500.00.

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COUNT 27: On or about February 23, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of JOHN L. of a value exceeding four hundred dollars ($400). To wit: $3,495.00.

COUNT 28: On or about January 01, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of ALLISON L. of a value exceeding four hundred dollars ($400). To wit: $3,995.00.

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COUNT 30: On or about August 04, 2008, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of DAVID M. of a value exceeding four hundred dollars ($400). To wit: $2,000.00.

COUNT 31: On or about and between January 15, 2009 and February 04, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of LETICIA P. of a value exceeding four hundred dollars ($400). To wit: $2,500.00.

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COUNT 33: On or about June 01, 2008, in violation of Section 487 (a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of EVA R. of a value exceeding four hundred dollars ($400). To wit: $1,500.00.

COUNT 34: On or about November 17, 2008, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of DOLORES S. of a value exceeding four hundred dollars ($400).To wit: $4,186.00.

(17)

COUNT 36: On or about January 15, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of ADRIEN S. of a value exceeding four hundred dollars ($400). To wit: $2,495.00.

COUNT 37: On or about December 01, 2008, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of WINSTON S. of a value exceeding four hundred dollars ($400). To wit: $3,995.00.

(18)

COUNT 39: On or about October 01, 2008, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of JONG T. of a value exceeding four hundred dollars ($400). To wit: $3,500.00.

COUNT 40: On or about August 21, 2008, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of JOSE T. of a value exceeding four hundred dollars ($400). To wit: $2,000.00.

(19)

COUNT 42: On or about November 24, 2008, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of JUDITH W. of a value exceeding four hundred dollars ($400). To wit: $3,000.00.

COUNT 43: On or about April 02, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of WILLIAM Y. of a value exceeding four hundred dollars ($400). To wit: $1,595.00.

(20)

COUNT 45: On or about March 05, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of SUSAN Z. of a value exceeding four hundred dollars ($400). To wit: $3,675.00.

COUNT 46: On or about July 09, 2009, in violation of Section 487 (a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of DAVID M. of a value exceeding four hundred dollars ($400). To wit: $750.00.

(21)

COUNT 48: On or about September 02, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of DONNA H. of a value exceeding four hundred dollars ($400). To wit: $2,995.00.

COUNT 49: On or about April 16, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of KIM H. of a value exceeding four hundred dollars ($400). To wit: $1,500.00.

(22)

COUNT 51: On or about January 20, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of LUCY K. of a value exceeding four hundred dollars ($400). To wit: $3,500.00.

COUNT 52: On or about March 05, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of MARY S. of a value exceeding four hundred dollars ($400). To wit: $1,590.00.

(23)

COUNT 54: On or about April 03, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of NADAL O. of a value exceeding four hundred dollars ($400). To wit: $500.00.

COUNT 55: On or about May 18, 2009, in violation of Section 487 (a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of RONALD P. of a value exceeding four hundred dollars ($400). To wit: $1,595.00.

(24)

COUNT 57: On or about December 16, 2008, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of VALERIE S. of a value exceeding four hundred dollars ($400). To wit: $1,695.00.

COUNT 58: On or about June 03, 2009, in violation of Section 487 (a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of LISSA S. of a value exceeding four hundred dollars ($400). To wit: $1,595.00.

(25)

COUNT 60: On or about March 17, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of SABINA A. of a value exceeding four hundred dollars ($400). To wit: $1,895.00.

COUNT 61: On or about February 23, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of APRIL A. of a value exceeding four hundred dollars ($400). To wit: $2,990.00.

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COUNT 63: On or about March 05, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of EVELYN J. of a value exceeding four hundred dollars ($400). To wit: $2,495.00.

COUNT 64: On or about January 23, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of KYLIE K. of a value exceeding four hundred dollars ($400). To wit: $3,995.00.

(27)

COUNT 66: On or about December 17, 2008, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of WEI L. of a value exceeding four hundred dollars ($400). To wit: $2,995.00.

COUNT 67: On or about December 22, 2008, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of HAI Q. and WEI Z. of a value exceeding four hundred dollars ($400). To wit: $3,495.00.

(28)

COUNT 69: On or about December 04, 2008, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of SANG JOUN P. of a value exceeding four hundred dollars ($400). To wit: $2,250.00.

COUNT 70: On or about December 04, 2008, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of JUNG JAE B. of a value exceeding four hundred dollars ($400). To wit: $2,250.00.

(29)

COUNT 72: On or about December 05, 2008, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of IN SUN P. of a value exceeding four hundred dollars ($400). To wit: $1,250.00.

COUNT 73: On or about December 16, 2008, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of HYUN WOO B. of a value exceeding four hundred dollars ($400). To wit: $2,500.00.

(30)

COUNT 75: On or about December 05, 2008, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of HYUN R. of a value exceeding four hundred dollars ($400). To wit: $2,000.00.

COUNT 76: On or about November 25, 2008, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of SANG M. of a value exceeding four hundred dollars ($400). To wit: $2,500.00.

(31)

COUNT 78: On or about February 18, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of MARVIN L. of a value exceeding four hundred dollars ($400). To wit: $2,595.00.

COUNT 79: On or about February 19, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of ANABEL M. of a value exceeding four hundred dollars ($400). To wit: $1,595.00.

(32)

COUNT 81: On or about and between January 26, 2009 and February 18, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of TIM P. of a value exceeding four hundred dollars ($400). To wit: $1,595.00.

COUNT 82: On or about and between February 26, 2009 and March 13, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of PEGGY S. of a value exceeding four hundred dollars ($400). To wit: $2,000.00.

(33)

COUNT 84: On or about and between September 01, 2009 and September 30, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of NEGAR T. of a value exceeding four hundred dollars ($400). To wit: $2,950.00

COUNT 85: On or about and between March 03, 2009 and March 27, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of HAROLINE W. of a value exceeding four hundred dollars ($400). To wit: $4,785.00.

(34)

COUNT 87: On or about December 12, 2008, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of WILLIAM B. of a value exceeding four hundred dollars ($400). To wit: $1,595.00.

COUNT 88: On or about and between October 01, 2008 and October 31, 2008, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of NANCY N. of a value exceeding four hundred dollars ($400). To wit: $3,495.00.

(35)

COUNT 90: On or about and between January 01, 2009 and January 31, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of TODD W. of a value exceeding four hundred dollars ($400). To wit: $1,695.00.

COUNT 91: On or about January 28, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of GERARDO C. of a value exceeding four hundred dollars ($400). To wit: $3,074.00.

(36)

COUNT 93: On or about and between December 01, 2008 and July 31, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of MMN - ARNOLD of a value exceeding four hundred dollars ($400). To wit: $130,000.00.

COUNT 94: On or about and between January 20, 2009 and April 13, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of GROUP ISO of a value exceeding four hundred dollars ($400). To wit: $204,618.00.

(37)

COUNT 96: On or about and between March 01, 2008 and October 31, 2008, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of UMS of a value exceeding four hundred dollars ($400). To wit: $354,445.00.

COUNT 97: On or about and between January 01, 2009 and April 30, 2009, in violation of Section 487(a) of the Penal Code (GRAND THEFT BY FALSE PRETENSE), a FELONY, CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR did unlawfully, knowingly, and designedly, by false and fraudulent representation and pretense, cause and procure others to report falsely of defendants's wealth and mercantile character, and by thus imposing upon another, obtained credit, and thereby fraudulently got possession of money and property, and obtained the labor and service, of MERITUS of a value exceeding four hundred dollars ($400). To wit: $36,697.00.

(38)

OTHER ALLEGATION(S) As to Count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55, 56, 57, 58, 59, 60, 61, 62, 63, 64, 65, 66, 67, 68, 69, 70, 71, 72, 73, 74, 75, 76, 77, 78, 79, 80, 81, 82, 83, 84, 85, 86, 87, 88, 89, 90, 91, 92, 93, 94, 95, 96, 97 and 98, it is further alleged pursuant to Penal Code section 1203.045(a) (OVER $100,000 LOSS), that defendants CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR committed the crime of theft of an amount exceeding one hundred thousand dollars ($100,000).

ENHANCEMENT(S) As to Count(s) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16, 17, 18, 19, 20, 21, 22, 23, 24, 25, 26, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51, 52, 53, 54, 55, 56, 57, 58, 59, 60, 61, 62, 63, 64, 65, 66, 67, 68, 69, 70, 71, 72, 73, 74, 75, 76, 77, 78, 79, 80, 81, 82, 83, 84, 85, 86, 87, 88, 89, 90, 91, 92, 93, 94, 95, 96, 97 and 98, it is further alleged pursuant to Penal Code section 12022.6(a)(3) (PROPERTY DAMAGE OVER $1,300,000), that CHRISTOPHER LEE DIENER, STEFANO JOSEPH MARRERO and TERRENCE LESEAN GREEN SR intentionally took, damaged, and destroyed property valued in excess of one million three hundred thousand dollars ($1,300,000) during the commission and attempted commission of the above offense.

(39)

I declare under penalty of perjury, on information and belief, that the foregoing is true and correct.

Dated 01-25-2010 at Orange County, California. GM/BO 10F00210

TONY RACKAUCKAS, DISTRICT ATTORNEY by:

Deputy District Attorney RESTITUTION CLAIMED

[ ] None

[ ] $________

[ X ] To be determined NOTICES:

The People request that defendant and counsel disclose, within 15 days, all of the materials and information described in Penal Code section 1054.3, and continue to provide any later-acquired materials and information subject to disclosure, and without further request or order.

Pursuant to Penal Code Section 296.1, defendant, CHRISTOPHER LEE DIENER, is required to provide DNA samples and thumb and palm prints.

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