SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES

THE PEOPLE OF THE STATE OF CALIFORNIA, Plaintiff,

CASE NO. BA397216

v.
01 RICHARD A. ALARCON (11/24/1953), and 02 FLORA MONTES DE OCA ALARCON (06/25/1965)
Defendant s . The undersigned is informed and believes that: COUNT 1

FELONY COMPLAINT FOR ARREST WARRANT

On or about November 9,2006, in the County of Los Angeles, the crime of PERJURY BY DECLARATION, in violation of PENAL CODE SECTION 118(a), a Felony, was committed by RICHARD

A. ALARCON, who did unlawfully, under penalty of perjury, declare as true a material matter that he knew to be false, to wit, in his Voter Registration Form, the "address where you live" was 14451 Nordhoff Street, Panorama City.

*****
COUNT 2

On or about November 20,2006, in the County of Los Angeles, the crime of PERJURY BY DECLARATION, in violation of PENAL CODE SECTION 118(a), a Felony, was committed by RICHARD

A. ALARCON; who did unlawfully, under penalty of perjury, declare as true, a material matter that he knew to be false, to wit: in his Declaration of Intent to solicit and receive campaign contributions, "residence address" was 14451 Nordhoff Street, Panorama City. that his

*****

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COUNT 3

On or about December 11, 2006, in the County of Los Angeles, the crime of FALSE DECLARATION OF·CANDIDACY, in violation of ELECTIONS CODE SECTION 18203, a Felony, was

committed by RICHARD A. ALARCON, who did unlawfully file, and submit for filing a Declaration for Candidacy which contained material information the he knew to be false, to wit, on his Declaration of Intention to become a Candidate for the Office of Member of the City Council, that his "residence address" was 14451 Nordhoff Street, Panorama City.

*****
COUNT 4

On or about December 11, 2006, in the County of Los Angeles, the crime of PERJURY BY DECLARATION, in violation of PENAL CODE SECTION 118(a), a Felony, was committed by RICHARD

A. ALARCON, who did unlawfully, under penalty of perjury, declare as true, a material matter that he knew to be false, to wit: in his Declaration to Become a Candidate for the Office of Member of the City Council, that his "residence address" was 14451 Nordhoff Street, Panorama City.

*****
COUNT 5

On and between January 22,2007 and January 27,2007, in the County of Los Angeles, the crime of PERJURY - APPLICATION FOR DRIVER'S LICENSE, in violation of PENAL CODE SECTION 118(a), a

Felony, was committed by RICHARD A. ALARCON, who being a person who testified, declared, deposed, and certified under penalty of perjury in a case in which such testimony, declaration, deposition, and certification is permitted by law under penalty of perjury, to wit, an application for a California Driver's License, did state as true as true a material matter which he/she knew to be false, to wit, that the "address where you live" was 14451 Nordhoff Street, Panorama City.

*****

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FELONY COMPLAINT FOR ARREST WARRANT

Case No. BA397216

COUNT 6

On or about March 6, 2007, in the County of Los Angeles, the crime of FRAUDULENT VOTING, in violation of ELECTIONS CODE SECTION 18560(a), a Felony, was committed by RICHARD A. ALARCON, who, while not being entitled to vote at an election, fraudulently voted and attempted to vote at an election.

*****
COUNT 7

On or about April 2, 2007, in the County of Los Angeles, the crime of PERJURY BY DECLARATION, in violation of PENAL CODE SECTION 118(a), a Felony, was committed by RICHARD

A. ALARCON, who did unlawfully, under penalty of perjury, declare as true, a material matter that he knew to be false, to wit: in his Voter Registration Form, that the "address where you live" is 14451 Nordhoff Street, Panorama City.

*****
COUNT 8

On or about April 3, 2007, in the County of Los Angeles, the crime of PERJURY - APPLICATION FOR DRIVER'S LICENSE, in violation of PENAL CODE SECTION 118(a), a Felony, was committed by RICHARD A. ALARCON, who being a person who testified, declared, deposed, and certified under penalty of perjury in a case in which such testimony, declaration, deposition, and certification is permitted by law under penalty of perjury, to wit, an application for a California Driver's License, did state as true a material matter which he/she knew to be false, to wit: that the "address where you live" is 14451 Nordhoff Street, Panorama City.

*****

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COUNT 9

On or about May 15,2007, in the County of Los Angeles, the crime of FRAUDULENT VOTING, in violation of ELECTIONS CODE SECTION 18560(a), a Felony, was committed by RICHARD A. ALARCON, who, while not being entitled to vote at an election, fraudulently voted and attempted to vote at an election.

*****
COUNT 10

On or about February 8, 2008, in the County of Los Angeles, the crime of FRAUDULENT VOTING, in violation of ELECTIONS CODE SECTION 18560(a), a Felony, was committed by RICHARD A. ALARCON, who, while not being entitled to vote at an election, fraudulently voted and attempted to vote at an election.

*****
COUNT 11

On or about April 7, 2008, in the County of Los Angeles, the crime of PERJURY BY DECLARATION, in violation of PENAL CODE SECTION 118(a), a Felony, was committed by FLORA

,MONTES DE OCA ALARCON, who did unlawfully, under penalty of perjury, declare as true, a material matter that she knew to be false, to wit: in her Driver's License Application Form, that the "address where you live" was 14451 Nordhoff Street, Panorama City.

*** **

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COUNT 12

On or about June 3, 2008, in the County of Los Angeles, the crime of FRAUDULENT VOTING, in violation of ELECTIONS CODE SECTION 18560(a), a Felony, was committed by RICHARD A. ALARCON, who; while not being entitled to vote at an election, fraudulently voted and attempted to vote at an election.

*****
COUNT 13

On or about October 8, 2008, in the County of Los Angeles, the crime of PERJURY BY DECLARATION, in violation of PENAL CODE SECTION 118(a), a Felony, was committed by RICHARD

A. ALARCON, who did unlawfully, under penalty of perjury, declare as true, a material matter that he knew to be false, to wit: in his Declaration of Intent to Solicit and Receive Contributions, that the "address where you live" was 14451 Nordhoff Street, Panorama City

*****
COUNT 14

On or about November 5, 2008, in the County of Los Angeles, the crime of FRAUDULENT VOTING, in violation of ELECTIONS CODE SECTION I 8560(a), a Felony, was committed by RICHARD A. ALARCON, who, while not being entitled to vote at an election, fraudulently voted and attempted to vote at an election.

*****

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COUNT 15

On or about November 4,2008, in the County of Los Angeles, the crime of PERJURY BY DECLARATION, in violation of PENAL CODE SECTION 118(a), a Felony, was committed by FLORA declare as true, a material

MONTES DE OCA ALARCON, who did unlawfully, under penalty ofpetjury,

matter that she knew to be false to wit: in her Provisional Ballot, that the "address where you live" was 14451 Nordhoff Street, Panorama City

*****
COUNT 16

On or about November 4,2008, in the County of Los Angeles, the crime of FRAUDULENT VOTING, in violation of ELECTIONS CODE SECTION 18560( a), a Felony, was committed by FLORA MONTES DE OCA ALARCON, who, while not being entitled to vote at an election, fraudulently voted and attempted to vote at an election.

*****
COUNT 17

On or about November 6,2008, in the County of Los Angeles, the crime of PERJURY BY DECLARATION, in violation of PENAL CODE SECTION 118(a), a Felony, was committed by RICHARD declare as true, a material matter that he knew

A. ALARCON, who did unlawfully, under penalty ofpetjury,

to be false, to wit: in his Declaration of Intention to Become a Candidate for Office of Member of the City Council, that the "address where you live" was 14451 Nordhoff Street, Panorama City

*****

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COUNT 18

On or about November 6,2008, in the County of Los Angeles, the crime of FALSIFY DECLARATION OF CANDIDACY, in violation of ELECTIONS CODE SECTION 18203, a Felony, was

committed by RICHARD A. ALARCON, who did unlawfully file, and submit for filing a Declaration for 'Candidacy which contained material information the he knew to be false, to wit, on his Declaration of Intention to become a Candidate for the Office of Member of the City Council, that his "residence address" was 14451 Nordhoff Street, Panorama City.

* ****
COUNT 19

On or about March 3,2009, in the County of Los Angeles, the crime of FRAUDULENT VOTING, in violation of ELECTIONS CODE SECTION 18560(a), a Felony, was committed by RICHARD A. ALARCON, who, while not being entitled to vote at an election, fraudulently voted and attempted to vote at an election.

*****
COUNT 20

On or about March 3,2009, in the County of Los Angeles, the crime of FRAUDULENT VOTING, in violation of ELECTIONS CODE SECTION 18560(a), a Felony, was committed by FLORA MONTES DE OCA ALARCON, who, while not being entitled to vote at an election, fraudulently voted and attempted to vote at an election.

*****

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COUNT 21

On or about May 19,2009, in the County of Los Angeles, the crime of FRAUDULENT VOTING, in violation of ELECTIONS CODE SECTION I8560(a), a Felony, was committed by RICHARD A. ALARCON, who, while not being entitled to vote at an election, fraudulently voted and attempted to vote at an election.

*****
COUNT 22

On or about May 19,2009, in the County of Los Angeles, the crime of FRAUDULENT VOTING, in violation of ELECTIONS CODE SECTION 18560(a), a Felony, was committed by FLORA MONTES DE OCA ALARCON, who, while not being entitled to vote at an election, fraudulently voted and attempted to vote at an election.

*****
COUNT 23

On or about June 18,2009, in the County of Los Angeles, the crime of PERJURY - APPLICATION FOR DRIVER'S LICENSE, in violation of PENAL CODE SECTION 118(a), a Felony, was committed by RICHARD A. ALARCON, who being a person who testified, declared, deposed, and certified under penalty of perjury in a case in which such testimony, declaration, deposition, and certification is permitted by law under penalty of perjury, to wit, an application for a California Driver's License, did state as true a material matter which he/she knew to be false, to wit: in his Driver's License Application (Duplicate), that the "address where you live" was 14451 Nordhoff Street, Panorama City.

*****

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FELONY COMPLAINT FOR ARREST WARRANT

COUNT 24

On or about June 18,2009, in the County of Los Angeles, the crime of PERJURY BY DECLARATION, in violation of PENAL CODE SECTION 118(a), a Felony, was committed by FLORA declare as true, a material

MONTES DE OC ALARCON, who did unlawfully, under penalty ofperjury,

matter which she knew was false, to wit: in her Driver's License Application, that the "address where you live" is 14451 Nordhoff Street, Panorama City.

*****
It is further alleged, as to counts 1 through 24, that the matters charged herein involve the same defendants and same conduct as were pending before the Los Angeles Superior Court from July 30,2010 to May 3,2012, in Case BA361169, filed on July 30, 2010, in Department 100 of the Los Angeles Superior Court, upon which defendants were arraigned and entered their pleas o~ August 3,2010 to August 4,2010, and was dismissed on May 3,2012, thereby tolling the statute oflimitations for the period of time that the

prosecution of the same persons for the same conduct was pending, pursuant to Penal Code Section 803(b).

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FELONY COMPLAINT FOR ARREST WARRANT

NOTICE: impressions impressions

Conviction pursuant is a crime.

of this offense will require the defendant

to provide DNA samples and print

to Penal Code sections 296 and 296.1. Willful refusal to provide the samples and

NOTICE: regarding

The People of the State of California all applicable circumstances

intend to present evidence and seek jury findings pursuant to Penal Code section 1170(b) and

in aggravation,

Cunningham v. California (2007) 549 U.S. 270.
NOTICE: Any allegation making a defendant ineligible to serve a state prison sentence in the county to Penal Code § 1385.

jail shall not be subject to dismissal pursuant

Further, attached hereto and incorporated herein are official reports and documents of a law enforcement agency which the undersigned believes establish probable cause for the arrest of defendant(s) RICHARD A. ALARCON and FLORA MONTES DE OC ALARCON for the above-listed crimes. Wherefore, a warrant of arrest is requested for RICHARD A. ALARCON and FLORA MONTES DE OC ALARCON.

I DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT AND THAT THIS COMPLAINT, CASE NUMBER BA397216, CONSISTS OF 24 COUNT(S).

Executed at LOS ANGELES, County of Los Angeles, on May 3,2012.

DAVID BABCOCK DECLARANT AND COMPLAINANT

STEVE COOLEY,

DISTRICT ATTORNEYBY:~

AGENCY:

DR NO.:

LACO D.A. BUREAU OF INVESTIGATION P090165

I/O: DAVID BABCOCK

ID NO.: 512828

PHONE: (213) 580-8763

OPERATOR:

SG

PRELIM. TIME EST.:

2 WEEK(S)

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Case No. BA397216

FELONY COMPLAINT FOR ARREST WARRANT

DEFENDANT ALARCON, RICHARD A. ALARCON, FLORA MONTES DE OC

ClINO.

DOB 11124/1953 . 6/25/1965

BOOKING NO.

BAIL RECOM'D $45,000 $25,000

CUSTODY R'TNDATE

It appearing to the Court that probable cause exists for the issuance of a warrant of arrest for the above-named defendant(s), the warrant is so ordered. BAIL: $ BAIL: $ _ _

RICHARD ALARCON FLORA ALARCON

DATE: Judge of the Above Entitled Court

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NON-WARRANT

DEFENDANTS:

DEFENDANT

CIINO.

BOOKING NO.

BAIL
RECOM'D

CUSTODY R'TNDATE

FELONY COMPLAINT -- ORDER HOLDING TO ANSWER -- P.C. SECTION 872
It appearing to me from the evidence presented that the following offense(s) has/have been committed and that there is sufficient cause to believe that the following defendant(s) guilty thereof, to wit:

(Strike out or add as applicable)

RICHARD A. ALARCON Count No. Charge 1 PC 118(a) 2 3 4 5 6 7 8 9 10 12 13 14 17 18 19 21 23 PC 118(a) EL 18203 PC 118(a) PC 118(a) EL 18560(a) PC 118(a) PC 118(a) EL 18560(a) EL 18560(a) EL 18560(a) PC 118(a) EL 18560(a) PC 118(a) EL 18203 EL 18560(a) EL 18560(a) PC 118(a)

Charge Range 2-3-4 County Jail 2-3-4 County Jail 2-3-4 County Jail 2-3-4 County Jail 16-2-3 County Jail 2-3-4 County Jail 2-3-4 County Jail 16-2-3 County Jail 16-2-3 County Jail 16-2-3 County Jail 2-3-4 County Jail 16-2-3 County Jail 2-3-4 County Jail 16-2-3 County Jail 16-2-3 County Jail 2-3-4 County Jail

S:gecial Allegation

Alleg. Effect

FLORA MONTES DE OC ALARCON Count No. Charge 11 PC 118(a)
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Charge Range 2-3-4 County

S:gecial Allegation

Alleg. Effect

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15 16 20 22 24

PC 118(a) EL 18560(a) EL 18560(a) EL 18560(a) PC 118(a)

Jail 2-3-4 County Jail 16-2-3 County Jail 16-2-3 County Jail 16-2-3 County Jail 2-3-4 County Jail

I order that the defendant(s) be held to answer therefore and be admitted to bail in the sum of: RICHARD A. ALARCON FLORA MONTES DE OC ALARCON _____________ _____________ Dollars DoUars

and be committed to the custody of the Sheriff of Los Angeles County until such bail is given. Date of arraignment in Superior Court will be:

RICHARD A. ALARCON FLORA MONTES DE OC ALARCON

__________ __________

in Dept in Dept

_ _

at:

A.M.

Date:

_ Committing Magistrate

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