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‘SUPERIOR COURT OF THE STATE OF CALIFORNIA, FOR THE COUNTY OF LOS ANGELES "THE PEOPLE OF THE STATE OF CALIFORNIA, ‘CASE NO. BAG60879 A Pitt, pi FELONY COMPLAINT piste arToRNErsOrRCE “The undersigned is informed and believes tha Err weST TEMPLE STREET, UTE 1000 108 ANGELES, CA 90012 NL 01 REFUGIO RODRIGUEZ (DOB: 0712197), and ‘NOL &2 ELIZABETH TINAJERO MELENDREZ. (0B: 091021972) Defendants count: On or eiween November 6, 2014 and May 19, 2015, inthe County of Los Angeles, the crime of CONSPIRACY TO COMMIT A CRIME, in violation of PENAL CODE SECTION 182(a)1), Felony, ‘was committed by REFUGIO RODRIGUEZ and ELIZABETH TINAJERO MELENDREZ, who did unlawfully conspire together to commit the crime of Assumed Name Contribution, in violation of Section £4301 of the Government Code, a misdemeanor; hat pursuant to and forthe purpose of carrying ou the objectives and purposes ofthe aforesaid conspiracy, he said defendants committed the following overt act and acts a and in the County of Los Anges: 1) On orsbout November 29,2014, Defendant Rodriguez and Defendant Melendtez organized a _gthering in order to begin fundraising for Defendant Rodriguez's campaign fora seat on the LAUSD Board of Education. 2) On or about December 19, 2014, Defendant Rodriguez cashed ou a $26,000 business 3) On and between December 19, 2014 and December 20, 2014, Defendant Rodriguez provided Defendant Melendre witha $2,000 check and Defendant Rodriguez provided Defendani Melendez wit instructions on what odo with the money. 4) On or about December 20, 2014, Defendant Melendrez deposited the money received From Defendant Rodriguez into an account inthe names of Defendant Rodriguez's parents 5) Onand between December 20,2014, and December 31, 2014, Defendnt Melendeez ‘caused Defendant Rodriguec's mother o sign sixteen checks dated between the aforementioned time period and made payable to farily and fiends who had “donated” money to Defendant Rodriguer’scampsign 6) Beginning on or about December 20,2014, Deendam Melendez delivered the sixteen checks aforementioned othe payers named therein, FELONY COMPLAINT 7) On and between December 20, 2014, and December 31, 2014, Defendant Melendrez