SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO

SAN BERNARDINO JUSTICE CENTER DISTRICT

THE PEOPLE OF THE STATE OF CALIFORNIA, ) COURT CASE NO

Plaintiff
vs.
Stephen Lyster Siringoringo ,
Alfred O. Clausen ,
Joshua Michael Cobb
Defendant

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FELONY COMPLAINT

DA CASE NO 2014-00-0037288

The undersigned is informed and believes that:

COUNT 1
On or about January 23, 2013 through July 29, 2013, in the above named judicial district,
the crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION
487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua
Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine
Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Everado Rincon .
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

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It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in

counts

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

are

related felonies, a material element of which is fraud and embezzlement, which involve a pattern of
related felony conduct, and the pattern of related felony conduct involves the taking of more than
one hundred thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 2
On or about January 23, 2013 through July 29, 2013, in the above named judicial district,
the crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN
MODIFICATION, in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by
Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform
a residential mortgage loan modification for a mortgage and/or deed of trust secured by residential
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real property containing four or fewer dwelling units, for a fee or compensation paid by the
borrower, and did willfully and unlawfully demand and/or receive preperformance compensation.
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 3
On or about March 6, 2013 through July 29, 2013, in the above named judicial district, the
crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION
487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua
Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine
Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Rolando Antonio
Hernandez .
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
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conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony

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conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 4
On or about March 6, 2013 through July 29, 2013, in the above named judicial district, the
crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,
in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster
Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential
mortgage loan modification for a mortgage and/or deed of trust secured by residential real property
containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did
willfully and unlawfully demand and/or receive preperformance compensation.
*****
COUNT 5
On or about December 14, 2012 through July 29, 2013, in the above named judicial district,
the crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION
487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua
Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine
Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Patricio Mendoza .
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

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It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 6
On or about December 14, 2012 through July 29, 2013, in the above named judicial district,
the crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN
MODIFICATION, in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by
Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform
a residential mortgage loan modification for a mortgage and/or deed of trust secured by residential
real property containing four or fewer dwelling units, for a fee or compensation paid by the
borrower, and did willfully and unlawfully demand and/or receive preperformance compensation.
*****
COUNT 7
On or about June 24, 2011 through July 29, 2013, in the above named judicial district, the
crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION
487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua
Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine
Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Emilio C. Magdaleno .
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
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conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 8
On or about June 24, 2011 through July 29, 2013, in the above named judicial district, the
crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,
in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster
Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential
mortgage loan modification for a mortgage and/or deed of trust secured by residential real property
containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did
willfully and unlawfully demand and/or receive preperformance compensation.
*****
COUNT 9
On or about May 6, 2013 through July 29, 2013, in the above named judicial district, the
crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION
487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua
Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine
Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Manuel Villalpando .
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

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It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 10
On or about May 6, 2013 through July 29, 2013, in the above named judicial district, the
crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,
in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster
Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential
mortgage loan modification for a mortgage and/or deed of trust secured by residential real property
containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did
willfully and unlawfully demand and/or receive preperformance compensation.
*****
COUNT 11
On or about August 31, 2012 through July 29, 2013, in the above named judicial district, the
crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION
487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua
Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine
Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Ana Audelia Lopez .
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
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conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 12
On or about August 31, 2012 through July 29, 2013, in the above named judicial district, the
crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,
in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster
Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential
mortgage loan modification for a mortgage and/or deed of trust secured by residential real property
containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did
willfully and unlawfully demand and/or receive preperformance compensation.
*****
COUNT 13
On or about May 21, 2013 through July 29, 2013, in the above named judicial district, the
crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION
487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua
Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine
Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Elias Salazar .
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It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 14
On or about May 21, 2013 through July 29, 2013, in the above named judicial district, the
crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,
in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster
Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential
mortgage loan modification for a mortgage and/or deed of trust secured by residential real property
containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did
willfully and unlawfully demand and/or receive preperformance compensation.
*****
COUNT 15
On or about July 17, 2013 through July 29, 2013, in the above named judicial district, the
crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION
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487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua
Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine
Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Martha Hernandez .
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 16
On or about July 17, 2013 through July 29, 2013, in the above named judicial district, the
crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,
in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster
Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential
mortgage loan modification for a mortgage and/or deed of trust secured by residential real property
containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did
willfully and unlawfully demand and/or receive preperformance compensation.
*****
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COUNT 17
On or about February 24, 2013 through July 29, 2013, in the above named judicial district,
the crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION
487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua
Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine
Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Lidia Osuma .
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 18
On or about February 24, 2013 through July 29, 2013, in the above named judicial district,
the crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN
MODIFICATION, in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by
Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform
a residential mortgage loan modification for a mortgage and/or deed of trust secured by residential
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real property containing four or fewer dwelling units, for a fee or compensation paid by the
borrower, and did willfully and unlawfully demand and/or receive preperformance compensation.
*****
COUNT 19
On or about July 18, 2012 through July 29, 2013, in the above named judicial district, the
crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION
487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua
Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine
Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Ramon Cano Rodriguez .
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 20
On or about July 18, 2013 through July 29, 2013, in the above named judicial district, the
crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,
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in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster
Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential
mortgage loan modification for a mortgage and/or deed of trust secured by residential real property
containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did
willfully and unlawfully demand and/or receive preperformance compensation.
*****
COUNT 21
On or about February 16, 2013 through July 29, 2013, in the above named judicial district,
the crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION
487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua
Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine
Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Douglas Ernesto Diaz .
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
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COUNT 22
On or about February 6, 2013 through July 29, 2013, in the above named judicial district,
the crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN
MODIFICATION, in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by
Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform
a residential mortgage loan modification for a mortgage and/or deed of trust secured by residential
real property containing four or fewer dwelling units, for a fee or compensation paid by the
borrower, and did willfully and unlawfully demand and/or receive preperformance compensation.
*****
COUNT 23
On or about March 26, 2012 through July 29, 2013, in the above named judicial district, the
crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION
487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua
Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine
Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Wanderlei B De Oliveria .
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony

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conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 24
On or about March 26, 2012 through July 29, 2013, in the above named judicial district, the
crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,
in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster
Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential
mortgage loan modification for a mortgage and/or deed of trust secured by residential real property
containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did
willfully and unlawfully demand and/or receive preperformance compensation.
*****
COUNT 25
On or about August 27, 2012 through July 29, 2013, in the above named judicial district, the
crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION
487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua
Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine
Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Oslett Antone .
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

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It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 26
On or about August 27, 2012 through July 29, 2013, in the above named judicial district, the
crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,
in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster
Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential
mortgage loan modification for a mortgage and/or deed of trust secured by residential real property
containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did
willfully and unlawfully demand and/or receive preperformance compensation.
*****
COUNT 27
On or about May 22, 2013 through July 29, 2013, in the above named judicial district, the
crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION
487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua
Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine
Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Guadalupe Barraza .
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
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conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 28
On or about May 22, 2013 through July 29, 2013, in the above named judicial district, the
crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,
in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster
Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential
mortgage loan modification for a mortgage and/or deed of trust secured by residential real property
containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did
willfully and unlawfully demand and/or receive preperformance compensation.
*****
COUNT 29
On or about July 16, 2012 through July 29, 2013, in the above named judicial district, the
crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION
487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua
Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine
Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Richard Hernandez .
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

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It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 30
On or about July 16, 2012 through July 29, 2013, in the above named judicial district, the
crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,
in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster
Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential
mortgage loan modification for a mortgage and/or deed of trust secured by residential real property
containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did
willfully and unlawfully demand and/or receive preperformance compensation.
*****
COUNT 31
On or about June 27, 2012 through July 29, 2013, in the above named judicial district, the
crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION
487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua
Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine
Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Diana M. Stanfield .
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
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conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 32
On or about June 27, 2012 through July 29, 2013, in the above named judicial district, the
crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,
in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster
Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential
mortgage loan modification for a mortgage and/or deed of trust secured by residential real property
containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did
willfully and unlawfully demand and/or receive preperformance compensation.
*****
COUNT 33
On or about July 4, 2013 through July 4, 2013, in the above named judicial district, the
crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION
487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua
Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine
Hundred Fifty Dollars ($950), to wit cash in the amount of the property of George Alexander .
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It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 34
On or about July 4, 2013 through July 4, 2013, in the above named judicial district, the
crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,
in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster
Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential
mortgage loan modification for a mortgage and/or deed of trust secured by residential real property
containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did
willfully and unlawfully demand and/or receive preperformance compensation.
*****
COUNT 35
On or about March 26, 2012 through July 29, 2013, in the above named judicial district, the
crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION
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487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua
Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine
Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Mercedes Caamal .
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 36
On or about March 26, 2012 through July 29, 2013, in the above named judicial district, the
crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,
in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster
Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential
mortgage loan modification for a mortgage and/or deed of trust secured by residential real property
containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did
willfully and unlawfully demand and/or receive preperformance compensation.
*****
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COUNT 37
On or about July 19, 2012 through July 29, 2013, in the above named judicial district, the
crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION
487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua
Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine
Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Maria F Resto .
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 38
On or about July 19, 2012 through July 29, 2013, in the above named judicial district, the
crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,
in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster
Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential
mortgage loan modification for a mortgage and/or deed of trust secured by residential real property
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containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did
willfully and unlawfully demand and/or receive preperformance compensation.
*****
COUNT 39
On or about July 1, 2012 through July 29, 2013, in the above named judicial district, the
crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION
487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua
Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine
Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Gloria Barajas .
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 40
On or about July 1, 2012 through July 29, 2013, in the above named judicial district, the
crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,
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in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster
Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential
mortgage loan modification for a mortgage and/or deed of trust secured by residential real property
containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did
willfully and unlawfully demand and/or receive preperformance compensation.
*****
COUNT 41
On or about June 1, 2012 through July 29, 2013, in the above named judicial district, the
crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION
487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua
Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine
Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Celia Marquez .
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
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COUNT 42
On or about June 1, 2012 through July 29, 2013, in the above named judicial district, the
crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,
in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster
Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential
mortgage loan modification for a mortgage and/or deed of trust secured by residential real property
containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did
willfully and unlawfully demand and/or receive preperformance compensation.
*****
COUNT 43
On or about May 29, 2013 through May 29, 2013, in the above named judicial district, the
crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION
487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua
Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine
Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Ronald Sweatt .
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony

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conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 44
On or about May 29, 2013 through May 29, 2013, in the above named judicial district, the
crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,
in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster
Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential
mortgage loan modification for a mortgage and/or deed of trust secured by residential real property
containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did
willfully and unlawfully demand and/or receive preperformance compensation.
*****
COUNT 45
On or about May 25, 2013 through May 25, 2013, in the above named judicial district, the
crime of GRAND THEFT OF PERSONAL PROPERTY, in violation of PENAL CODE SECTION
487(a), a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua
Michael Cobb, who did unlawfully take money and personal property of a value exceeding Nine
Hundred Fifty Dollars ($950), to wit cash in the amount of the property of Gerardo Herrera Villa .
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

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It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 46
On or about May 25, 2013 through May 25, 2013, in the above named judicial district, the
crime of UNLAWFUL ACTIVITIES IN CONJUNCTION WITH MORTGAGE LOAN MODIFICATION,
in violation of CIVIL CODE SECTION 2944.7, a misdemeanor, was committed by Stephen Lyster
Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did offer to perform a residential
mortgage loan modification for a mortgage and/or deed of trust secured by residential real property
containing four or fewer dwelling units, for a fee or compensation paid by the borrower, and did
willfully and unlawfully demand and/or receive preperformance compensation.
*****
COUNT 47
On or about January 19, 2012 through January 19, 2012, in the above named judicial
district, the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a
felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael
Cobb, who did unlawfully conduct and attempt to conduct a transaction involving a monetary
instrument or instruments of a value exceeding 170,000 through a financial institution with the
intent to promote, manage, establish, carry on, and facilitate the promotion, management,
establishment, and carrying on of criminal activity, to wit: grand theft, and knowing that the
monetary instrument represented the proceeds of, and was derived directly or indirectly from the
proceeds of, criminal activity.
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).
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It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 48
On or about April 4, 2012 through April 4, 2012, in the above named judicial district, the
crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony, was
committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did
unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or
instruments of a value exceeding 240,000 through a financial institution with the intent to promote,
manage, establish, carry on, and facilitate the promotion, management, establishment, and
carrying on of criminal activity, to wit: grand theft, and knowing that the monetary instrument
represented the proceeds of, and was derived directly or indirectly from the proceeds of, criminal
activity.
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

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It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 49
On or about April 19, 2012 through April 19, 2012, in the above named judicial district, the
crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony, was
committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did
unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or
instruments of a value exceeding 320,000 through a financial institution with the intent to promote,
manage, establish, carry on, and facilitate the promotion, management, establishment, and
carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that
the monetary instrument represented the proceeds of, and was derived directly or indirectly from
the proceeds of, criminal activity.
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
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material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 50
On or about May 2, 2012 through May 2, 2012, in the above named judicial district, the
crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony, was
committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did
unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or
instruments of a value exceeding 200,000 through a financial institution with the intent to promote,
manage, establish, carry on, and facilitate the promotion, management, establishment, and
carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that
the monetary instrument represented the proceeds of, and was derived directly or indirectly from
the proceeds of, criminal activity.
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony

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conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 51
On or about May 10, 2012 through May 12, 2012, in the above named judicial district, the
crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony, was
committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did
unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or
instruments of a value exceeding 180,000 through a financial institution with the intent to promote,
manage, establish, carry on, and facilitate the promotion, management, establishment, and
carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that
the monetary instrument represented the proceeds of, and was derived directly or indirectly from
the proceeds of, criminal activity.
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).
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It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 52
On or about May 17, 2012 through May 17, 2012, in the above named judicial district, the
crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony, was
committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did
unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or
instruments of a value exceeding 258,000 through a financial institution with the intent to promote,
manage, establish, carry on, and facilitate the promotion, management, establishment, and
carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that
the monetary instrument represented the proceeds of, and was derived directly or indirectly from
the proceeds of, criminal activity.
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

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It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 53
On or about May 21, 2012 through May 21, 2012, in the above named judicial district, the
crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony, was
committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did
unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or
instruments of a value exceeding 200,000 through a financial institution with the intent to promote,
manage, establish, carry on, and facilitate the promotion, management, establishment, and
carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that
the monetary instrument represented the proceeds of, and was derived directly or indirectly from
the proceeds of, criminal activity.
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
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material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 54
On or about June 12, 2012 through June 12, 2012, in the above named judicial district, the
crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony, was
committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did
unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or
instruments of a value exceeding 200,000 through a financial institution with the intent to promote,
manage, establish, carry on, and facilitate the promotion, management, establishment, and
carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that
the monetary instrument represented the proceeds of, and was derived directly or indirectly from
the proceeds of, criminal activity.
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony

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conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 55
On or about June 28, 2012 through June 28, 2012, in the above named judicial district, the
crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony, was
committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did
unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or
instruments of a value exceeding 400,000 through a financial institution with the intent to promote,
manage, establish, carry on, and facilitate the promotion, management, establishment, and
carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that
the monetary instrument represented the proceeds of, and was derived directly or indirectly from
the proceeds of, criminal activity.
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).
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*****
COUNT 56
On or about July 3, 2012 through July 3, 2012, in the above named judicial district, the
crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony, was
committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did
unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or
instruments of a value exceeding 200,000 through a financial institution with the intent to promote,
manage, establish, carry on, and facilitate the promotion, management, establishment, and
carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that
the monetary instrument represented the proceeds of, and was derived directly or indirectly from
the proceeds of, criminal activity.
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
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COUNT 57
On or about July 11, 2012 through July 11, 2012, in the above named judicial district, the
crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony, was
committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did
unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or
instruments of a value exceeding 310,000 through a financial institution with the intent to promote,
manage, establish, carry on, and facilitate the promotion, management, establishment, and
carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that
the monetary instrument represented the proceeds of, and was derived directly or indirectly from
the proceeds of, criminal activity.
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 58

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On or about July 18, 2012 through July 18, 2012, in the above named judicial district, the
crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony, was
committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did
unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or
instruments of a value exceeding 375,000 through a financial institution with the intent to promote,
manage, establish, carry on, and facilitate the promotion, management, establishment, and
carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that
the monetary instrument represented the proceeds of, and was derived directly or indirectly from
the proceeds of, criminal activity.
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 59
On or about July 25, 2012 through July 25, 2012, in the above named judicial district, the
crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony, was
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committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did
unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or
instruments of a value exceeding 460,000 through a financial institution with the intent to promote,
manage, establish, carry on, and facilitate the promotion, management, establishment, and
carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that
the monetary instrument represented the proceeds of, and was derived directly or indirectly from
the proceeds of, criminal activity.
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 60
On or about August 3, 2012 through August 3, 2012, in the above named judicial district, the
crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony, was
committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who did
unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or
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instruments of a value exceeding 450,000 through a financial institution with the intent to promote,
manage, establish, carry on, and facilitate the promotion, management, establishment, and
carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that
the monetary instrument represented the proceeds of, and was derived directly or indirectly from
the proceeds of, criminal activity.
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 61
On or about August 10, 2012 through August 10, 2012, in the above named judicial district,
the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony,
was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who
did unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or
instruments of a value exceeding 340,000 through a financial institution with the intent to promote,
manage, establish, carry on, and facilitate the promotion, management, establishment, and
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carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that
the monetary instrument represented the proceeds of, and was derived directly or indirectly from
the proceeds of, criminal activity.
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 62
On or about August 15, 2012 through August 15, 2012, in the above named judicial district,
the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony,
was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who
did unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or
instruments of a value exceeding 400,000 through a financial institution with the intent to promote,
manage, establish, carry on, and facilitate the promotion, management, establishment, and
carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that

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the monetary instrument represented the proceeds of, and was derived directly or indirectly from
the proceeds of, criminal activity.
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 63
On or about August 23, 2012 through August 23, 2012, in the above named judicial district,
the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony,
was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who
did unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or
instruments of a value exceeding 400,000 through a financial institution with the intent to promote,
manage, establish, carry on, and facilitate the promotion, management, establishment, and
carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that
the monetary instrument represented the proceeds of, and was derived directly or indirectly from
the proceeds of, criminal activity.
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It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 64
On or about August 30, 2012 through August 30, 2012, in the above named judicial district,
the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony,
was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who
did unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or
instruments of a value exceeding 433,000 through a financial institution with the intent to promote,
manage, establish, carry on, and facilitate the promotion, management, establishment, and
carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that
the monetary instrument represented the proceeds of, and was derived directly or indirectly from
the proceeds of, criminal activity.
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
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material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 65
On or about September 6, 2012 through September 6, 2012, in the above named judicial
district, the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a
felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael
Cobb, who did unlawfully conduct and attempt to conduct a transaction involving a monetary
instrument or instruments of a value exceeding 450,000 through a financial institution with the
intent to promote, manage, establish, carry on, and facilitate the promotion, management,
establishment, and carrying on of criminal activity, to wit: grand theft and the taking of up front
fees, and knowing that the monetary instrument represented the proceeds of, and was derived
directly or indirectly from the proceeds of, criminal activity.
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony

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conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 66
On or about September 13, 2012 through September 13, 2012, in the above named judicial
district, the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a
felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael
Cobb, who did unlawfully conduct and attempt to conduct a transaction involving a monetary
instrument or instruments of a value exceeding 550,000 through a financial institution with the
intent to promote, manage, establish, carry on, and facilitate the promotion, management,
establishment, and carrying on of criminal activity, to wit: grand theft and the taking of up front
fees, and knowing that the monetary instrument represented the proceeds of, and was derived
directly or indirectly from the proceeds of, criminal activity.
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).
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It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 67
On or about September 19, 2012 through September 19, 2012, in the above named judicial
district, the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a
felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael
Cobb, who did unlawfully conduct and attempt to conduct a transaction involving a monetary
instrument or instruments of a value exceeding 350,000 through a financial institution with the
intent to promote, manage, establish, carry on, and facilitate the promotion, management,
establishment, and carrying on of criminal activity, to wit: grand theft and the taking of up front
fees, and knowing that the monetary instrument represented the proceeds of, and was derived
directly or indirectly from the proceeds of, criminal activity.
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

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It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 68
On or about September 27, 2012 through September 27, 2012, in the above named judicial
district, the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a
felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael
Cobb, who did unlawfully conduct and attempt to conduct a transaction involving a monetary
instrument or instruments of a value exceeding 300,000 through a financial institution with the
intent to promote, manage, establish, carry on, and facilitate the promotion, management,
establishment, and carrying on of criminal activity, to wit: grand theft and the taking of up front
fees, and knowing that the monetary instrument represented the proceeds of, and was derived
directly or indirectly from the proceeds of, criminal activity.
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
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material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 69
On or about October 3, 2012 through October 3, 2012, in the above named judicial district,
the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a felony,
was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael Cobb, who
did unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or
instruments of a value exceeding 500,000 through a financial institution with the intent to promote,
manage, establish, carry on, and facilitate the promotion, management, establishment, and
carrying on of criminal activity, to wit: grand theft and the taking of up front fees, and knowing that
the monetary instrument represented the proceeds of, and was derived directly or indirectly from
the proceeds of, criminal activity.
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony

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conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 70
On or about October 10, 2012 through October 10, 2012, in the above named judicial
district, the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a
felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael
Cobb, who did unlawfully conduct and attempt to conduct a transaction involving a monetary
instrument or instruments of a value exceeding 200,000 through a financial institution with the
intent to promote, manage, establish, carry on, and facilitate the promotion, management,
establishment, and carrying on of criminal activity, to wit: grand theft and the taking of up front
fees, and knowing that the monetary instrument represented the proceeds of, and was derived
directly or indirectly from the proceeds of, criminal activity.
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).
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It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 71
On or about October 11, 2012 through October 11, 2012, in the above named judicial
district, the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a
felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael
Cobb, who did unlawfully conduct and attempt to conduct a transaction involving a monetary
instrument or instruments of a value exceeding 400,000 through a financial institution with the
intent to promote, manage, establish, carry on, and facilitate the promotion, management,
establishment, and carrying on of criminal activity, to wit: grand theft and the taking of up front
fees, and knowing that the monetary instrument represented the proceeds of, and was derived
directly or indirectly from the proceeds of, criminal activity.
It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

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It is further alleged, pursuant to Penal Code section 186.11(a)(3), that the offenses set forth
in counts 1,3,5,7,9,11,13,15,17,19,21,23,25,27,29,31,33,35,37,39,41,43,45 are related felonies, a
material element of which is fraud and embezzlement, which involve a pattern of related felony
conduct, and the pattern of related felony conduct involves the taking of more than one hundred
thousand dollars ($100,000).

*****
COUNT 72
On or about June 24, 2011 through July 29, 2013, in the above named judicial district, the
crime of CONSPIRACY TO COMMIT A CRIME, in violation of PENAL CODE SECTION 182(a)(1),
a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael
Cobb, who did unlawfully conspire together and with another person and persons whose identity is
unknown to commit the crime of grand theft, in violation of Section 487 of the penal Code, a felony;
that pursuant to and for the purpose of carrying out the objects and purposes of the aforesaid
conspiracy, the said defendant(s)s committed the following overt act and acts at and in the County
of San Bernardino: Overt Act 1
Stehen Lyster Siringo, an attorney licensed to practice law in the state of California, entered into a
contract with Alfred Clausen and Joshua Cobb, (both non attorneys) to perform loan modifications.

Overt Act 2
Alfred Clausen and Josh Cobb formed an S Corporation known as Clausen and Cobb
Management, Inc. (CCMI). CCMI provided the day to day management, hiring, personnel, training,
advertising and equipment for Siringoringo Law Firm.

Overt Act 3
Employees of Clausen and Cobb Management were instructed to examine the bank accounts of
the victims who went to Sinringoringo Law Firm seeking loan modifications to determine how much
money could be taken. This policy was stressed in Friday sales meeting where Siringoringo,
Clausen and Cobb were present.

Overt Act 4
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Funds via ACH and check were collected from victims and deposited into a Pass Through Account
of Siringoringo Law Firm, then into the Clausen and Cobb Management account. Siringoringo was
paid a percentage of the funds taken from the victims.

Overt Act 5
Meetings were held every Friday between Siringoringo, Clausen and Cobb to divide all funds
received in cash. These funds were never deposited into any business accounts.

Overt Act 6
Alfred Clausen instructed account manager Daisy Salas to contact Andrew Palosi to create fake
invoices for advertising to cover unreported cash payments made by victims.

Overt Act 7
Josh Cobb acted as President on the ADP payroll accounts for both Siringoringo Law Firm and
Clausen and Cobb Management.

Overt Act 8
Alfred Clausen instructed contact managers and team leaders to collect as many outstanding client
payments as possible when it was learned that Siringoringo was facing disciplinary action from the
California State Bar.

Overt Act 9
At the weekly sales meetings, Siringoringo, Clausen and Cobb instructed the employees to
concentrate on Spanish speaking victims because "they don't understand the laws".
.
*****
COUNT 73
On or about June 24, 2011 through July 29, 2013, in the above named judicial district, the
crime of CONSPIRACY TO COMMIT A CRIME, in violation of PENAL CODE SECTION 182(a)(1),
a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael
Cobb, who did unlawfully conspire together and with another person and persons whose identity is
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unknown to commit the crime of Taking of up front fees, in violation of Section 2944.7 of the Civil
Code, a felony; that pursuant to and for the purpose of carrying out the objects and purposes of the
aforesaid conspiracy, the said defendant(s)s committed the following overt act and acts at and in
the County of San Bernardino: Overt Act 1
Stehen Lyster Siringo, an attorney licensed to practice law in the state of California, entered into a
contract with Alfred Clausen and Joshua Cobb, (both non attorneys) to perform loan modifications.

Overt Act 2
Alfred Clausen and Josh Cobb formed an S Corporation known as Clausen and Cobb
Management, Inc. (CCMI). CCMI provided the day to day management, hiring, personnel, training,
advertising and equipment for Siringoringo Law Firm.

Overt Act 3
Employees of Clausen and Cobb Management were instructed to examine the bank accounts of
the victims who went to Sinringoringo Law Firm seeking loan modifications to determine how much
money could be taken. This policy was stressed in Friday sales meeting where Siringoringo,
Clausen and Cobb were present.

Overt Act 4
Funds via ACH and check were collected from victims and deposited into a Pass Through Account
of Siringoringo Law Firm, then into the Clausen and Cobb Management account. Siringoringo was
paid a percentage of the funds taken from the victims.

Overt Act 5
Meetings were held every Friday between Siringoringo, Clausen and Cobb to divide all funds
received in cash. These funds were never deposited into any business accounts.

Overt Act 6
Alfred Clausen instructed account manager Daisy Salas to contact Andrew Palosi to create fake
invoices for advertising to cover unreported cash payments made by victims.

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Overt Act 7
Josh Cobb acted as President on the ADP payroll accounts for both Siringoringo Law Firm and
Clausen and Cobb Management.

Overt Act 8
Alfred Clausen instructed contact managers and team leaders to collect as many outstanding client
payments as possible when it was learned that Siringoringo was facing disciplinary action from the
California State Bar.

Overt Act 9
At the weekly sales meetings, Siringoringo, Clausen and Cobb instructed the employees to
concentrate on Spanish speaking victims because "they don't understand the laws".
.
*****
COUNT 74
On or about June 24, 2011 through July 28, 2013, in the above named judicial district, the
crime of CONSPIRACY TO COMMIT A CRIME, in violation of PENAL CODE SECTION 182(a)(1),
a felony, was committed by Stephen Lyster Siringoringo, Alfred O. Clausen and Joshua Michael
Cobb, who did unlawfully conspire together and with another person and persons whose identity is
unknown to commit the crime of Money Laundering, in violation of Section 186.10 of the Penal
Code, a felony; that pursuant to and for the purpose of carrying out the objects and purposes of the
aforesaid conspiracy, the said defendant(s)s committed the following overt act and acts at and in
the County of San Bernardino: Overt Act 1
Stehen Lyster Siringo, an attorney licensed to practice law in the state of California, entered into a
contract with Alfred Clausen and Joshua Cobb, (both non attorneys) to perform loan modifications.

Overt Act 2
Alfred Clausen and Josh Cobb formed an S Corporation known as Clausen and Cobb
Management, Inc. (CCMI). CCMI provided the day to day management, hiring, personnel, training,
advertising and equipment for Siringoringo Law Firm.

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Overt Act 3
Employees of Clausen and Cobb Management were instructed to examine the bank accounts of
the victims who went to Sinringoringo Law Firm seeking loan modifications to determine how much
money could be taken. This policy was stressed in Friday sales meeting where Siringoringo,
Clausen and Cobb were present.

Overt Act 4
Funds via ACH and check were collected from victims and deposited into a Pass Through Account
of Siringoringo Law Firm, then into the Clausen and Cobb Management account. Siringoringo was
paid a percentage of the funds taken from the victims.

Overt Act 5
Meetings were held every Friday between Siringoringo, Clausen and Cobb to divide all funds
received in cash. These funds were never deposited into any business accounts.

Overt Act 6
Alfred Clausen instructed account manager Daisy Salas to contact Andrew Palosi to create fake
invoices for advertising to cover unreported cash payments made by victims.

Overt Act 7
Josh Cobb acted as President on the ADP payroll accounts for both Siringoringo Law Firm and
Clausen and Cobb Management.

Overt Act 8
Alfred Clausen instructed contact managers and team leaders to collect as many outstanding client
payments as possible when it was learned that Siringoringo was facing disciplinary action from the
California State Bar.

Overt Act 9
At the weekly sales meetings, Siringoringo, Clausen and Cobb instructed the employees to
concentrate on Spanish speaking victims because "they don't understand the laws".
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DA CASE NO: 2014-00-0037288

.
*****

NOTICE TO DEFENDANT AND DEFENDANTS ATTORNEY

Pursuant to Penal Code Sections 1054.5.(b), the People are hereby informally requesting that
defense counsel provide discovery to the People as required by Penal Code Section 1054.3.
NOTICE TO ATTORNEY
The materials accompanying this notice may include information about witnesses. If so, these
materials are disclosed to you pursuant to Penal Code section 1054.2 which provides: "No
attorney may disclose or permit to be disclosed to a defendant the address or telephone number of
a victim or witness whose name is disclosed to the attorney pursuant to subdivision (a) of Section
1054.1 unless specifically permitted to do so by the court after a hearing and a showing of good
cause."

I DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND

CORRECT AND THAT THIS COMPLAINT CONSISTS OF 74 COUNT(S).
Executed at San Bernardino, California, on March 5, 2015.

Salvador Apodaca
Salvador Apodaca
DECLARANT AND COMPLAINANT

Agency: District Attorney B of I-REF

Defendant
Stephen Lyster Siringoringo
Alfred O. Clausen
Joshua Michael Cobb

Birth Date
03/09/1981
06/05/1973
10/31/1982

Prelim Est. 00:00

Booking No.

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CII No.

NCIC