Ort of ne Aro Gon sss gt ee 0 IND |ADAM PAUL LAXALT FILED IN OPEN COURT [Attorney General ‘STEVEN .GRIERSON RAYAM, SWIFT CLERK OF THE COURT | Senior Deputy Attorney General Nevada Bar No.: 11108 OCT - 5 2016 rswift@ag.nv.gov [Office of the Attorney General /555 East Washington Ave., Ste. 3900 Las Vegas, Nevada 89101 P: (702) 486-3396 FF: (702) 486-0660, Attorneys for State of Nevada ippeeeenr ce neehd ead ALANBROL CASTLE, SR, DEPUTY DISTRICT COURT CLARK COUNTY, NEVADA ‘THE STATE OF NEVADA, Case No.: C-16-318521-1 ) ) Plains, ; Dept. No: x RENAESTHER STARKS, aka.RENEE STARKS, a.k.a. RENA STARKS, ) Defendant ; INDICTMENT The above named defendant, RENA ESTHER STARKS a.k.a. RENEE STARKS| a.k.a, REN'A STARKS (hereinafter "STARKS'), is accused by the Clark County Grand Jury} lof the crimes(s) of three (3) counts of THEFT IN THE AMOUNT OF $3,500 OR MORE, a [category “B" felony in violation of NR'S 205.0832, two (2) counts of THEFT IN THE AMOUNT| |OF $650 OR MORE, a category °C" felony in violation of NRS 205.0832, and one (1) count of} [Multiple Transactions of Fraud and Deceit in Course of Enterprise or Occupation, a category +B" felony in violation of NRS 205.377, in Clark County, State of Nevada as follows: COUNT 4 N ‘CATEGORY “B” FELONY - NRS 20! ‘That the Defendant, STARKS, in the County of Clark, State of Nevada, by virtue of her| MORE Jown actions or by the actions of her agents or employees, without lawful authority, did knowingly: control property of another person with the intent to deprive that person of the|58 Wagon tee, ae 100 26 7 28 property; andior convert, make an unauthorized transfer of an interest in, oF withou! authorizaticn control property of another person, or used the services or propery of another person entusted to her or placed in her possession for a limited, authorized period of determined or prescribed duration or for a limited use; andlor obtain property or services of another person by a material misrepresentation with intent to deprive that person of the property orservices, and the value of said property was $3,500 or more, to wit From on or around May 19, 2015 to July 3, 2018, STARKS knowingly, and with the Intent to deprive LISA SHEPPERSON-GARNHART of her property, misrepresented to LISA| [SHEPPERSON-GARNHART and VERONICA FRESCAS that using her immigration connections, STARKS would obtain American citizenship for HECTOR GARCIA FLORES anal berate him from custody, all of which was untrue. Relying upon these misrepresentations, LISA SHE?PERSON-GARNHART paid STARKS $7,500 and $6,850, totaling fourteen| thousand, tree hundred and fity dallas ($14,350). {All of which constitutes the crime of THEFT IN THE AMOUNT OF $3,500 OR MORE, a category “8 felony, in violation NRS 208.0832, count 2 CATEGORY "B" FEL Baz ‘That the Defendant, STARKS, in the County of Clark, State of Nevada, aid withou! lawful authority knowingly: control property of another person with the intent to deprive that [person of the property; and/or convert, make an unauthorized transfer of an interest in, or without autnorization control property of another person, or used the services or property of Jancther peison entrusted to her or placed in her possession for a limited, authorized period of| Jdetermined or prescribed duration or for a limited use; and/or obtain property or services of Jancther person by a material misrepresentation with intent to deprive that person of the! property or services, and the value of said property was $3,500 or more, to wit Fiom on or aiournd September 22, 2014 to Deveber 17, 2014, STARKS knowingly, [and with the intent to deprive LESBIA ORTIZ, of her property, misrepresented to LESBIA, JORTIZ that she was an attomey and would obtain American citizenship for WALFER OMAR)ceo the Atoroey General HERNANDEZ ORTIZ and liberate him from custody by obtaining a letter from President| JObama demanding WALFER OMAR HERNANDEZ ORTIZ release, allof which was untrue, Relying upon these misrepresentations, LESBIA ORTIZ paid STARKS $4,000, $2,200, and '$1,500, totaling seven thousand, seven hundred dollars ($7,700). All of which constitutes the crime of THEFT IN THE AMOUNT OF $3,500 OR MORE, felony, in violation NRS 205.0832 COUNT 3 ‘THEFT IN THE AMOUNT OF $650 OR MORE ‘CATEGORY “C” FELONY -NRS 205.0832 ‘That the Defendant, STARKS, in the County of Clark, State of Nevada, did without lawful authority knowingly: control property of another person with the intent to deprive that} category “ person of the property; and/or convert, make an unauthorized transfer of an interest in, of without authorization control property of another person, or used the services or property of} another person entrusted to her or placed in her possession for a limited, authorized period of} Jdelermined or prescribed duration or for a limited use; and/or obtain property or services of} Janother person by a material misrepresentation with intent to deprive that person of the property or services, and the value of said property was $650 or more, to wit From on or around September 3, 2014 to April 1, 2015, STARKS knowingly, and with the intent to deprive JOSE ANTONIO CARDENAS LUGO, of his property, misrepresented to hin that STARKS would obtain American citizenship for him, diverting the ‘normar' immigration process by taking his files directly to Washington D.C., all of which was untrue. Relying upon these misrepresentations, JOSE ANTONIO CARDENAS LUGO paid STARKS| '$190, $100, $750, $250, and $250, totaling one thousand, four hundred and fity dollars ($1,450), Al of which constitutes the crime of THEFT IN THE AMOUNT OF $650 OR MORE, a| ‘category °C" felony, in violation NRS 205.0832. 7 in av900 fe ote Atorny ever a Ve Nevede 107 couNT4 IN THE Al ‘OF $3500 OR MORE OR ‘CATEGORY “B” FELONY - NRS 208.0832 ‘That the Defendant, STARKS, in the County of Clark, State of Nevada, did without lawful authorty knowingly: control property of another person with the intent to deprive that person of the property; and/or convert, make an unauthorized transfer of an interest in, o |without authorization control property of another person, oF used the services or property of another person entrusted to her or placed in her possession for a limited, authorized period of determined or prescribed duration or for a limited use; and/or obtain property or senices off another person by @ material misrepresentation with intent to deprive that person of the! property or services, and the value of said property was $3,500 or more, to wit From on or around December 5, 2014 to April, 2108, STARKS knowingly, and with the intent to deprive MARIA MUNGUIA, of her property, misrepresented to MARIA MUNGUIA and) DEISY VILLAGRANA that by using STARKS' immigration connections, STARKS would) obtain American citizenship for GILBERTO VILLAGRANA PANDURO and JOSE ROJAS and) liberate them from custody, and that STARKS would also renew DEISY VILLAGRANA's grant! of Deferred Action for Childhood Arrivals (DACA), all of which was untrue, Relying upon these} misrepresentations, MARIA MUNGLIA paid STARKS $600, $2,000, $155, $550, $350, '$5,000, $1,000, $3,500, and $500, totaling thirteen thousand, six hundred and fiy-fve dollars (613,655), All of which constitutes the crime of THEFT IN THE AMOUNT OF $3,500 OR MORE, a| felony, in violation NRS 205.0832, COUNTS THEFLINTHE AMOUNT OF e859 08 MORE ‘That the Defendant, STARKS, in the County of Clark, State of Nevada, did without lawful authority knowingly: control property of another person with the intent to deprive that} person of the property; andor convert, make an unauthorized transfer of an interest in, of} |without authorization control property of another person, or used the services or property of another person entrusted to her or placed in her possession for a limited, authorized period of}Office fhe Atrney Genet 58x Watgn ave, ae 3900 10 u 2 B 4 1s 16 7 18 19 20 21 2 23 24 25 26 u 28 determined or prescribed duration or for a limited use; andlor obtain property or services of another person by a material mistepresentation with intent to deprive that person of the| property or services, and the value of said property was $3,500 or more, to wit: From on or around June §, 2014 to April 2, 2315, STARKS knowingly, and with the| Intent to deprive JULIO PAZOS VARGAS, of his property, misrepresented to him that [STARKS would obtain American citizenship andlor travel visas for him and his relatives, all of| lwhich was untrue. Relying upon these misrepreseniations, JULIO PAZOS VARGAS paid /STARKS $350, $1,750 and $75, totaling two thousand, one hundred and seventy-five dollars, (62,178). z All of which constitutes the crime of THEFT IN THE AMOUNT OF $650 OR MORE, a ‘category "C" felony, in violation NRS 205.0832. COUNT 6. MULTIPLE TRANSACTIONS INVOLVING FRAUD OR DECEIT IN COURSE OF ENTERPRISE OR OCCUPATION CATEGORY “B" FELONY — NRS 208.377 Defendant, STARKS in the County of Clark, State of Nevada, either by virtue of their own actions or by the actions of their agents or employees, in the course of an enterprise or} loccupation, knowingly and with the intent to defraud, engaged in an act, practice or course of} business, or employed a device scheme or artifice which operated or would have operated as} ‘a fraud or deceit upon a person by means of a false representation or omission of a material {fact that: she knew to be false or omitted; that she intended another to rely on; and which] resulted in a loss to @ person who relied on the false representation or omission, in at least two transactions having the same or similar pattem, intents, results, accomplices, vicims or] methods of commission, or which were otherwise intentlated by distinguishing characteristics} ‘and were not isolated incidents within 4 years and in which the aggregate loss or intended loss was more than $650, to wit ‘Aa sot forth in Counte One through Five, which are hereby incorporated by referoneo| as though fully set forth herein, Defendant STARKS, ether by virtue of her own actions or by the actions of her agents or employees, knowingly and intentionally defrauded individuals in|Oficn of he Arne Genera 58 Eat Wagon daa 3700 two oF more transactions as set forth mere full in those courts from between about Juno 2014 and July, 2015. As stated in Counts One through Five, Defendant, inthe course of an enterprise oF occupation, solicited money from her clients forthe purported purpose of helping them obtain citizenship for themselves or ther family members or prevent deportation of thei family members. The purposes, results and methods of commission in alinstances were the same or similar. All of which constitutes the cme of MULTIPLE TRANSACTIONS INVOLVING FRAUD] JOR DECEIT IN COURSE OF ENTERPRISE OR OCCUPATION, a category “8 felony in violation of NRS 205.377, Al of which is contrary tothe form, force and effect of the statutes in such cases made and provided, and against the peace and cig ofthe State of Nevada, paren tis Hay of october, 2006. ‘ADAM PAUL LAXALT ‘Attorney General By: s/ Ray Senior Deputy Attorney General ENDORSEMENT: A True Bill By: ‘Oreperson, Clark County Grand Jury ‘GUHTEAGIOGOX