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Sowmrxanukun I 12 13 15 16 17 18 19 20 21 22 23 24 23 26 27 28 IND STEVEN B, WOLFSON Clark County District Attomey Nevada Bar #00] 565 JAY P. RAMAN Chief Deputy District Attomey 0193 == 200 Lewis Avenue Las Vegas, Nevada 89155-2212 (702) 671-2500 Attorney for Plaintiff DISTRICT COURT CLARK COUNTY, NEVADA THE STATE OF NEVADA, Plaintiff, CASE NO: C-17-320381-1 “VS DEPTNO: IV ROBERT GRAHAM #5062044 AME! Defendant. INDICTMENT STATE OF NEVADA) ss. COUNTY OF CLARK The Defendant above named, ROBERT GRAHAM, accused by the Clark County Grand Jury of the crime(s) of EXPLOITATION OF OLDER/VULNERABLE PERSONS (Category B Felony - NRS 200.5092, 200.5099 - NOC 50304) and THEFT (Category B Felony - NRS 205.0832, 205.0835.4 - NOC 55991) committed at and within the County of Clark, State of Nevada, on or between January 1, 2011 and December 11, 2016, as follows: COUNT |- EXPLOITATION OF OLDER/VULNERABLE PERSONS did on or between January 1, 2011 and December 11, 2016 willfully, unlawfully and feloniously exploit an persons 60 years of age or older and vulnerable persons, by Defendant, having the trust or confidence of the victims or by use of a power of attomey or guardianship, obtain control, through deception, intimidation or undue influence, over the victims’ money, assets or property and/or by converting victims’ money, assets or property, Defendant intending to permanently deprive the victims” of the ownership, use, benefit or possession of sAHIBIT “1” Wun aa AC SHI6AGISN apn Al tt. ee Soman aw hun I 12 13 15 16 17 18 19 20 al 2 23 4 25 26 27 28 their money, assets or property having an value of more than $5,000.00, by acting in the capacity of attorney for the victims, through Robert Graham and Associates and/or Lawyers West unlawfully converted the money of victims under guardianships, from the following victims-in the following amounts: ee ae Victim Guardianship Amount of Exploitation Davis, Frederick - Guardianship $114,579.28 Pena, Michelle - Guardianship $72,072.53, Benson, Allen - Guardianship $290,417.10 Itzkowitz, Sue - Guardianship $10,095.09 Bryson, Baird - Guardianship _____ $1,500.00 | Clark, Barbara - Guardianship | $58,142.47 | Miller, Regina - Guardianship $10,468.12 ‘Munar, Brian - Guardianship $68,668.67 Pena, Jose - Guardianship $39,172.00 Brown, Mabel - Guardianship $13,721.84 Total Exploitation of Guardianships $678,837.10 | COUNT 2- EXPLOITATION OF OLDER/VULNERABLE PERSONS did on or between January 1, 2011 and December 11, 2016 willfully, unlawfully and feloniously exploit an persons 60 years of age or older and vulnerable persons, by Defendant, having the trust or confidence of the victims or by use of a power of attorney or guardianship, obtain control, through deception, intimidation or undue influence, over the victims’ money, assets or property and/or by converting victims’ money, assets or property, Defendant intending to permanently deprive the victims” of the ownership, use, benefit or possession of their money, assets or property having an value of more than $5,000.00, by acting in the capacity of attomey for the victims, through Robert Graham and Associates and/or Lawyers West unlawfully converted the money of victims who had special needs trusts, from the following victims in the following amounts: Victim of Special Needs Trust Amount of Exploitation Dagani, Sharona - Special Needs $523,814.09 2 an aiematsnes.0ROPORED AMENDED INDICTMENT) 1 DOCH . 1 | | Parton, Thane ~ Special Needs Trust| $487,006.86 Gale, Matthew - Special Needs $522,406.83, 2 | | Ostrovksy, Zane - Special Needs $18,089.35 3 ssisieeass eee i._| Total Exploitation $1,551,317.13 5 | COUNT3- EXPLOITATION OF OLDER/VULNERABLE PERSONS 6 did on or between January 1, 2011 and December 11, 2016 willfully, unlawfully and 7 | feloniously exploit an persons 60 years of age or older and vulnerable persons, by Defendant, 8 || having the trust or confidence of the victims or by use of a power of attorney or guardianship, 9 ]| obtain control, through deception, intimidation or undue influence, over the victims’ money, 10 | assets or property and/or by converting victims’ money, assets or property, Defendant 11 || intending to permanently deprive the victims’ of the ownership, use, benefit or possession of 12 | their money, assets or property having an value of more than $5,000.00, by acting in the 13. | capacity of attomey for the victims, through Robert Graham and Associates and/or Lawyers 14 | West unlawfully converted the money of victims who had trusts, from the following victims 15 || in the following amounts: 16 7 Victims of Trusts Amount of Exploitation 1g | | Miller, Micaela, Noah & Madison - Trust $941,914.09 McKinney, Bileen - Trust of $92,626.59 19 | | Caldwell-Riley - Trust of $18,160.80 20 | | Fine, Dale - Trust $213,716.36 91 | Dugan, Joseph L. - Trust of $69.97 Friedman, Ken - Administration $55,960.91 22 | | Cannon, Harvey - Trust $1,500.00 23 | | Bell, Bessie - Trust Administration $240,444.55 Kinsler, Ellen - Trust Administration $11,514.92 24 | | Trejbal, Carol - Trust Administration $4,382.90 25 || | Estrada, James & Virginia - Trust $2,000.00 76 | nik, Hene - Trust Administration $115,495.72 | 27 || | Glotzer, Stanley - Trust Administration $28,231.80 28 | | Adams, Anthony - Trust Administration | $20,000.00 3 ‘W-sorsaneAGnsisAGie.No @noROSeD AMENDED, RDNETMAENT 201 D0Cx Sow rwxan kun Miltenberger, Jimmie - Trust Admin, $580,738.28 | (Owens, Margarette - Trust $399,576.16 Griffith, James - Trust Administration $0.00 Radford, Judith - Trust Adi tion as __ $1,060.00 | Dupuis, Verla - Trust Administration $8,189.43 Watts, Sharyl = Trust Administration $10,300.19 | Lacy, Joseph - Trust $39,981.46 Perkins, Earlie Mae - Trust $15,017.84 Total amount of Exploitation $2,800,881.97 COUNT 4- THEFT did on or between January 1, 2011 and December 11, 2016, willfully, knowingly, feloniously, and without lawful authority, use the services or property of another person entrusted to him, or placed in his possession for a limited, authorized period of determined or prescribed duration or for a limited use, having a value of $3,500.00 or more, belonging to estates and probates of clients that had retained Robert Graham and Associates and/or Lawyers West and by using said position to unlawfully convert and/or spend and/or transfer funds entrusted to Robert Graham and Associates and/or Lawyers West, from the following victims’ estates: Victim Estate/Probate Amount of Theft White, Charlotte - Estate of $142,910.89 Grzych, Antonetta - Estate of $59,240.14 Carleton, Laura - Estate of iff $221,590.73 LaHue, Maurice - Estate of "$594,261.50 Wheeler, Rae Alan - Estate of $1,045,133.69 Lentino, Elaine - Estate of { $131,225.88 Francisco, Anthony - Estate of | $23,937.37 Sicho, Luz - Estate of $124,052.66 Graham, Mary - Estate of $185.24 Henry, Paul J. - Estate of $8,035.53 | Hampton, James T. - Estate of $388.94 4 ‘ aorsznencinsvsncisesNo,PnOPOSED, AMENDED MOIETIES DOCK Kapfer, Dieter-Estateof_ = $6,744.37. 1 | Miilpert, Myra E. - Estate of $7,288,859.84 2 || (Lee, Lois — Estate of $575,001.90 4 | | ily, Carol — Estate of $965,982.18 |_| Parton, Tranquillino - Estate of $95,597.30 _ || | Piper, Franklin — Estate of $348,985.04 > | [Nakazono, Mikio ~ Estate of ae ~_ $470,850.96 | 6 Kerr, Barbara — Estate of $47,453.93 | Macknin, Michael - Estate of $1,045,335.08 7 | |Fachini, Kim-Estateof oe $37,592.89 8 | | Ivey, Pamela - Estate of $14,290.39 9 Haythorn, Trapper John - Estate $92,792.67 10 | [Francis, Carol - Estate of sea $20,862.89 Kotanchik, Paul - Estate of = $173,860.48 11 | | Stroka, Lorraine - Estate of $110,930.54 12 | | Ward, Joshua Frank - Estate of $78,201.38 | 13 | | Gray, Gary - Estate of $162,247.78 14 | | Cabrera, Vicente - Estate of $267,506.44 Salcedo, Erlinda - Estate of $3,000.00 15 | | Herrmann, Earl - Estate of ie $223,476.73 16 || | McKeever, Maureen - Estate of $51,061.52 17 || | Christie, Carl, Estate of $77,648.13 1g | | Coker. Jeanne Estate of $61,311.62 Stauffer, Ronald - Estate of $452.97 19 | | McCann, Harry - Estate of ia $215,917.54 20 | | Hildebrand, Brian - Estate of $1,874.09 Forman, Marcia - Estate of $68,248.59 21 Banova, Giancarlo - Estate of $54,984.94 n Myers, Veda - Estate of $25,999.71 Friedman, Allen - Estate of ae $1,000.00 23 Covay, Kenneth - Estate of $123,602.60 24 | Freeman, Michael - Estate of $114,506.52 Kanezzel - Estate of $1,720.00 25 England, Gary - Estate of $40,523.91 3g | [Hawk Robin Estate of $215,083.59 Colley, David E. - Estate of $22,868.45 27 | | Pepper, Joanna - Estate of $20.00 28 Mitchell, Herbert - Estate of $20,577.17 LE waniesisnaiissucagns.0-¢AorOSED AMENDUD,MDIETAENT)-H DOCK +1 || |. MacCrossen, Virginia I - Estate $8,996.81, 2 || [Zeutzius, Walter - Estate of $29,576.59 Birchall, Barbara - Estate of $2,500.00 3 | Pfeifer, Ronald - Estate of $105,642.67 4_| (Lewis, Dixie L. - Estate of | $531.00 Abdale, Pearl - Estate of _ $826.36 5 | (Jones, Celia - Estate of $4,829.03 6 | | Gaffney, Lawrence - Estate of $4,860.80 Kessler, Sylvia - Probate $232,563.79 | 7 | [ West, William F. - Probate zi $5,000.00 8 Ledford, Shirley A. - Probate $72,687.80 Bradley, Beverly - Probate $102,454.18 9 | | DeBaro, Vincent - Probate $217,131.46 10 | [Cole, Donna Marie - Probate $267,108.82 yy | (Tomes: Tomas Estate of $22,672.16 12 | | Total amount of Theft from 13 | LEstates/Probate $10,555,318.18 14 | COUNT 5 - THEFT Is did on or between January 1, 2011 and December 11, 2016, willfully, knowingly, 16 | feloniously, and without lawful authority, use the services or property of another person 17 | entrusted to him, or placed in his possession for a limited, authorized period of determined or 18 | prescribed duration or for a limited use, having a value of $3,500.00 or more, belonging to 19 | clients that had retained Robert Graham and Associates and/or Lawyers West and by using 20 | said position to unlawfully convert and/or spend and/or transfer funds entrusted to Robert 21 | Graham and Associates and/or Lawyers West, from the following victims’ for various legal 22 | services: B 4 25 | [Victims from Miscelanous Attorney Representation Amount of Theft Dee, Ada - Litigation $25,005.65 26 | | Wilde, Ryan - Litigation $1,000.00 27 || | Argus Enterprises $1,000.00 ag || [Revord, Edeltraud - Litigation $74,707.68 Schrage, Ruediger - Litigation $108,400.00 6 WupiasiancinssusnaskmD

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