10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 FILED TORI VERBER SALAZAR SUPERIOR COURTSTOCKTON District Attorney SEP 27 2021 san Joaquin County BRAN State Bar No. 213636 By RILEY, CLE By: Kelly McDaniel Deputy District Attorney ae 222 E. Weber Avenue Stockton, CA 95202 209.468.2400; Fax 209.465.0371 Attorneys for Plaintiff SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN JOAQUIN Stockton, Branch ew-crimem-oa.- (qu The People of the State of California, No. S019-18106, So19- 18779, 8020-19603, SP19- Plaintiff, 52296 SO CASE ve DA Case: CR-2021-4240576 COMPLAINT ZAKIR KHAN ‘SPE MOHAMMAD IQBAL KHAN Defendant (s). I, the undersigned, say, on information and belief, that in the County of SAN JOAQUIN, State of California: COUNT 1: PERMITTING PLACE TO BE USED FOR BETTING ACTIVITIES PC.337a(a) (5) On or about February 14, 2018 - September 7, 2020, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of PERMITTING PLACE TO BE USED FOR BETTING ACTIVITIES, in violation of10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 California Penal Code Section 337a(a)5, a FELONY, who at the time and place last aforesaid, did willfully, unlawfully and knowingly, being the owner, lessee or occupant of any place, permit that space to be used or occupied for bookmaking, or pool selling, or recording/registering of bets, or holding/receiving/forwarding of bets, to wit: AMERICAN SMOKERS CLUB AT 2620 £ WATERLOO RD. #2, STOCKTON, CA. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: COUNT 2: PERMITTING PLACE TO BE USED FOR BETTING ACTIVITIES PC.337a(a) (5) on or about February 4, 2020 - October 28, 2020, in the County of San Joaquin, California, ZAKIR KHAN, did commit the crime of PERMITTING PLACE TO BE USED FOR BETTING ACTIVITIES, in violation of California Penal Code Section 337a(a)5, a FELONY, who at the time and place last aforesaid, did willfully, unlawfully and knowingly, being the owner, lessee or occupant of any place, permit that space to be used or occupied for bookmaking, or pool selling, or recording/registering of bets, or holding/receiving/forwarding of bets, to wit: ONE STOP SMOKE SHOP AT 2525 E FREMONT ST., STOCKTON, cA. "Nv 10 1 12 13 14 15 16 17 18 19 20 21 22 23 24 26 28 For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s above, complainant further complains and says COUNT 3: PERMITTING PLACE TO BE USED FOR BETTING ACTIVITIES PC.337a(a) (5) On or about February 13, 2020 - September 7, 2020, in the County of San Joaquin, California, MOHAMMAD IQBAL KHAN and ZAKIR KHAN, did commit the crime of PERMITTING PLACE TO BE USED FOR BETTING ACTIVITIES, in violation of California Penal Code Section 337a(a)5, a FELONY, who at the time and place last aforesaid, did willfully, unlawfully and knowingly, being the owner, lessee or occupant of any place, permit that space to be used or occupied for bookmaking, or pool selling, or recording/registering of bets, or holding/receiving/forwarding of bets, to wit: AMERICAN SMOKERS CLUB AT 2620 E WATERLOO RD. #2, STOCKTON, CA. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: COUNT 4: PERMITTING PLACE TO BE USED FOR BETTING ACTIVITIES PC. 337a(a) (5) On or about December 12, 2019 - October 28, 2020, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime ofsw nr 10 ql 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PERMITTING PLACE TO BE USED FOR BETTING ACTIVITIES, in violation of California Penal Code Section 337a(a)5, a FELONY, who at the time and place last aforesaid, did willfully, unlawfully and knowingly, being the owner, lessee or occupant of any place, permit that space to be used or occupied for bookmaking, or pool selling, or recording/registering of bets, or holding/receiving/forwarding of bets, to wit: ONE STOP SMOKE SHOP AT 2525 E FREMONT ST., STOCKTON, ca. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: ‘COUNT FALSE STATEMENT/ETC REGARDING UNEMPLOYMENT COMPENSATION UI.2101 (a) (1) On or about August 2, 2020, in the County of San Joaquin California, SHAKIR KHAN, did commit the crime of FALSE STATEMENT/ETC REGARDING UNEMPLOYMENT COMPENSATION, in violation of Section 2101(A) (1) of the Unemployment Insurance Code, a FELONY, who at the time and place last aforesaid, did willfully and unlawfully make a false statement or representation, or knowingly fail to disclose a material fact, or to use a false name, or false social security number, or other false identification to obtain, increase, reduce or defeat any benefit or payment to said defendant(s) or any other person under the statute administered by the Employment Development10 12 13 Department, to wit: SHAKIR KHAN. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: COUNT 6: FALSE STATEMENT/ETC REGARDING UNEMPLOYMENT COMPENSATION UI.2101 (a) (1) On or about August 2, 2020, in the County of San Joaquin California, SHAKIR KHAN, did commit the crime of FALSE STATEMENT/ETC REGARDING UNEMPLOYMENT COMPENSATION, in violation of Section 2101(A) (1) of the Unemployment Insurance Code, a FELONY, who at the time and place last aforesaid, did willfully and unlawfully make a false statement or representation, or knowingly fail to disclose a material fact, or to use a false name, or false social security number, or other false identification to obtain, increase, reduce or defeat any benefit or payment to said defendant(s) or any other person under the statute administered by the Employment Development Department, to wit: RAHEELA ZAMAN For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says " "13 14 15 16 17 18 19 20 21 23 24 25 26 27 COUNT 7: FALSE STATEMENT/ETC REGARDING UNEMPLOYMENT COMPENSATION UI.2101 (a) (1) on or about August 22, 2020, in the County of San Joaquin California, SHAKIR KHAN, did commit the crime of FALSE STATEMENT/ETC REGARDING UNEMPLOYMENT COMPENSATION, in violation of Section 2101(A) (1) of the Unemployment Insurance Code, a FELONY, who at the time and place last aforesaid, did willfully and unlawfully make a false statement or representation, or knowingly fail to disclose a material fact, or to use a false name, or false social security number, or other false identification to obtain, increase, reduce or defeat any benefit or payment to said defendant(s) or any other person under the statute administered by the Employment Development Department, to wit: SHER A. KHAN. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says COUNT 8: FALSE STATEMENT/ETC REGARDING UNEMPLOYMENT COMPENSATION UE.2101 (a) (1) On or about August 22, 2020, in the County of San Joaquin California, SHAKIR KHAN, did commit the crime of FALSE STATEMENT/ETC REGARDING UNEMPLOYMENT COMPENSATION, in violation of Section 2101(A) (1) of the Unemployment Insurance Code, a FELONY, who at the time and place last aforesaid, did willfully and unlawfully make a10 11 12 13 14 is 16 17 18 20 21 22 23 24 25 26 27 28 false statement or representation, or knowingly fail to disclose a material fact, or to use a false name, or false social security number, or other false identification to obtain, increase, reduce. or defeat any benefit or payment to said defendant(s) or any other person under the statute administered by the Employment Development Department, to wit: SABIR JAN For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: COUNT FALSE STATEMENT/ETC REGARDING UNEMPLOYMENT COMPENSATION UI.2101 (a) (1) On or about August 29, 2020, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of FALSE STATEMENT/ETC REGARDING UNEMPLOYMENT COMPENSATION, in violation of Section 2101(A) (1) of the Unemployment Insurance Code, a FELONY, who at the time and place last aforesaid, did willfully and unlawfully make a false statement or representation, or knowingly fail to disclose a material fact, or to use a false name, or false social security number, or other false identification to obtain, increase, reduce, or defeat any benefit or payment to said defendant(s) or any other person under the statute administered by the Employment Development Department, to wit: SHAGUFTA BIBI.10 1. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s above, complainant further complains and says: COUNT 10: FALSE STATEMENT/ETC REGARDING UNEMPLOYMENT COMPENSATION UL.2101 (a) (1) on or about August 31, 2020, in the County of San Joaquin’ California, SHAKIR KHAN, did commit the crime of FALSE STATEMENT/ETC REGARDING UNEMPLOYMENT COMPENSATION, in violation of Section 2101(A) (1) of the Unemployment Insurance Code, a FELONY, who at the time and place last aforesaid, did willfully and unlawfully make a false statement or representation, or knowingly fail to disclose a material fact, or to use a false name, or false social security number, or other false identification to obtain, increase, reduce or defeat any benefit or payment to said defendant(s) or any other person under the statute administered by the Employment Development Department, to wit: TASLEEM BEGUM For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: COUNT 11: FALSE STATEMENT/ETC REGARDING UNEMPLOYMENT COMPENSATION UI.2101 (a) (1) On or about August 31, 2020, in the County of San Joaquin,10 11 12 13 14 15 16 18 19 20 21 22 23 24 25 26 28 California, SHAKIR KHAN, did commit the crime of FALSE STATEMENT/ETC REGARDING UNEMPLOYMENT COMPENSAT. ION, in violation of Section 2101(A) (1) of the Unemployment Insurance Code, a FELONY, who at the time and place last aforesaid, did willfully and unlawfully make a false statement or representation, or knowingly fail to disclose a material fact, or to use a false name, or false social security number, or other false identification to obtain, increase, reduce or defeat any benefit or payment to said defendant(s) or any other person under the statute administered by the Employment Development Department, to wit: SIDRA AHMED Por a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s above, complainant further complains and says: COUNT 12: FALSE STATEMENT/ETC REGARDING UNEMPLOYMENT COMPENSATION UI.2101 (a) (1) On or about August 31, 2020, in the County of San Joaquin California, SHAKIR KHAN, did commit the crime of FALSE STATEMENT/ETC REGARDING UNEMPLOYMENT COMPENSATION, in violation of Section 2101(A) (1) of the Unemployment Insurance Code, a FELONY, who at the time and place last aforesaid, did willfully and unlawfully make a false statement or representation, or knowingly fail to disclose a material fact, or to use a false name, or false social security number, or other false identification to obtain, increase, reduce,ol aya JO (Z) (2)OT*98T UOTIDes Jo UOTIETOTA UT ‘SaaaQONd JO ONTYAANAYT KANOW FO SWTID 8Yy3 ZTUMOD PTP ‘NWHY UIMWHS ‘eTUTOFTTeD ‘uTNbeoe ues yo Aqunog oy2 UT ‘gTOZ ‘OE Ttadw - BIOZ ‘LZ Ttady qnoge to uO (2) (®) 01° 98T'Dd SGaa0%d JO ONINZGNAWI AENOW ‘PT LNOOD iskes pue sutetduoo zeyzang yueuteTduos ‘saoge (s) e6xeyo 043 YITA UOTSsTuMIOD SIT UT peIDeuUOD Inq WoIy esUETIO querez3Tp e buteq ‘qureTduos yo asnes eqeredes pue reyzIny e Iog “SLISNSE ZONWUNSNI LNZWAOTAWEND GO ‘WINYOAITYO JO SLWLS !aTM-02 /(00'0S6$) SZBTIOP AIZTI perpuny eutu Hutpeeoxe enTea e Jo zeyqoue go Ajxedord Teuosred pue Aevow ayeq ATTNJMeTUN pue ATINITITM PIP ‘presexoye set eoeTd pue out; syz 3e oYM /ANOTEG & ‘epg TeUEG 93 FO (P)L8y UOTIO9g JO UOTIETOTA UT /AIMBAOUd/YOAWT/AINOW: LAGHL CNWYD JO SUFI ey} FyUMIOD PTP ‘NYHN UINWHS ‘ETUTOFTTeD ‘uTNbeop ues yo Kyuno ey ut ‘0zoz ‘zz Tequezdes - ozoz ‘z ysnBmy ynoge Io uo (W) £86 "Dd AIMBAOWd/MOMWI/AANOW: LAMHL GNWHD <€T LNNOD rskes pue sutetduoo reuqanz queutetduos ‘eaoge (s)e6xeyo |y2 YITA UoTSsstumoD S3T UT pezoeuUCD ang WoIy esUEzzO querezyyp e buyeq ‘quTeTduios zo esneo eqeredes pue zeyzINJ e roa “C3WHY HSIWAS :37 03 ‘juewjTedeq quoudotesed quewXoTdug ou3 Aq pezeqsTuTmpe a3nqe3s sy3 zepun uosied zeyjo Aue zo (s)juepuesep pes 03 zueused z0 zt zeteq Aue jeazep ZO az Lz 9z sz bz &z zz 1% oz 6 8 ut 9 St eT €t zu IT ot am10 11 12 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding twenty-five thousand dollars ($25,000.00), to wit: $191,897.25, through one or more financial institutions knowing that the monetary instrument represented the proceeds of, and was derived directly or indirectly from the proceeds of, criminal activity, to wit: ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: COUNT 15: MONEY LAUNDERING OF PROCEEDS PC.186.10(a) (2) On or about October 30, 2018 - November 28, 2018, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of MONEY LAUNDERING OF PROCEEDS, in violation of Section 186.10(a) (2) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding twenty-five thousand dollars ($25,000.00), to wit: $230,871.75, through one or more financial institutions knowing that the monetary instrument represented the proceeds of, and was derived directly or indirectly ILLEGAL GAMBLING IN from the proceeds of, criminal activity, to wi ul10 11 12 13 14 1s 16 17 18 19 20 21 22 23 24 25 26 27 28 VIOLATION OF PENAL CODE 337a. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: COUNT 16: MONEY LAUNDERING OF PROCEEDS PC.186.10(a) (2) On or about December 3, 2018 - December 28, 2018, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of MONEY LAUNDERING OF PROCEEDS, in violation of Section 186.10(a) (2) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding twenty-five thousand dollars ($25,000.00), to wit: $58,314.75, through one or more financial institutions knowing that the monetary instrument represented the proceeds of, and was derived directly or indirectly from the proceeds of, criminal activity, to wit: ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s above, complainant further complains and says: COUNT 17: MONEY LAUNDERING OF PROCEEDS PC.186.10(a) (2) On or about January 2, 2019 - February 1, 2019, in the County of San 210 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Joaquin, California, SHAKIR KHAN, did commit the crime of MONEY LAUNDERING OF PROCEEDS, in violation of Section 186.10(a) (2) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding twenty-five thousand dollars ($25,000.00), to wit: $48,517.00, through one or more financial institutions knowing that the monetary instrument represented the proceeds of, and was derived directly or indirectly from the proceeds of, criminal activity, to wit: ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: COUNT 18: MONEY LAUNDERING OF PROCEEDS PC.186.10(a) (2) On or about April 1, 2019 - May 1, 2019, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of MONEY LAUNDERING OF PROCEEDS, in violation of Section 186.10(a) (2) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding twenty-five thousand dollars ($25,000.00), to wit: $551,254.85, through one or more financial institutions knowing that the monetary instrument represented the proceeds of, and was derived directly or indirectly B10 a1 12 13 14 16 17 18 19 20 21 22 23 24 25 26 27 28 from the proceeds of, criminal activity, to wit: ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: COUNT 19: FACILITATING MONEY LAUNDERING PC.186.10(a) (1) On or about July 29, 2019, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of FACILITATING MONEY LAUNDERING, in violation of Section 186.10(a) (1) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding five thousand dollars ($5,000.00), to wit; $20,500.00, through one or more financial institutions with the intent to promote, manage, establish, carry on, and facilitate the promotion, management, establishment, and carrying on of criminal activity, to wit: ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: W 410 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 COUNT 20: MONEY LAUNDERING OF PROCEEDS PC.186.10(a) (2) on or about September 3, 2019 - October 3, 2019, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of MONEY LAUNDERING OF PROCEEDS, in violation of Section 186.10(a) (2) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding twenty-five thousand dollars ($25,000.00), to wit: $38,432.00, through one or more financial institutions knowing that the monetary instrument represented the proceeds of, and was derived directly or indirectly from the proceeds of, criminal activity, to wit: ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: COUNT 21: MONEY LAUNDERING OF PROCEEDS PC.186.10(a) (2) On or about October 4, 2019 - November 1, 2019, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of MONEY LAUNDERING OF PROCEEDS, in violation of Section 186.10(a) (2) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding twenty-five thousand dollars ($25,000.00), to wit: $41,657.00, through one or 1swn sm oO 10 11 12 13 14 15 16 a7 18 19 20 21 22 23 24 25 26 27 28 more financial institutions knowing that the monetary instrument represented the proceeds of, and was derived directly or indirectly from the proceeds of, criminal activity, to wit: ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: COUNT 22: FACILITATING MONEY LAUNDERING PC.186.10(a) (1) On or about November 4, 2019, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of FACILITATING MONEY LAUNDERING, in violation of Section 186.10(a) (1) of the Penal Code a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding five thousand dollars ($5,000.00), to wit: $19,109.00, through one or more financial institutions with the intent to promote, manage, establish, carry on, and facilitate the promotion, management, establishment, and carrying on of criminal activity, to wit: ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: 16Bw Nn 10 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 COUNT 23: FACILITATING MONEY LAUNDERING PC.186.10(a) (1) On or about November 13, 2019 - November 15, 2019, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of FACILITATING MONEY LAUNDERING, in violation of Section 186.10(a) (1) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding five thousand dollars ($5,000.00), to wit: $15,000.00, through one or more financial institutions with the intent to promote, manage, establish, carry on, and facilitate the promotion, management, establishment, and carrying on of criminal activity, to wit: ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: COUNT 24: FACILITATING MONEY LAUNDERING PC.186.10(a) (1) On or about November 22, 2019, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of FACILITATING MONEY LAUNDERING, in violation of Section 186.10(a) (1) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction nvolving a monetary instrument or instruments of a value exceeding twenty five thousand dollars ($25,000.00), to wit: $29,512.00, through one or more "aoe wn 10 1. 12 13 14 15 16 17 18 19 20 al a2 23 24 25 26 27 28 financial institutions with the intent to promote, manage establish, carry on, and facilitate the promotion, management, establishment, and carrying on of criminal activity, to wit: ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: COUNT 25: FACILITATING MONEY LAUNDERING PC.186.10(a) (1) On or about December 18, 2019, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of FACILITATING MONEY LAUNDERING, in violation of Section 186.10(a) (1) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding five thousand dollars ($5,000.00), to wi : $19,100.00, through one or more financial institutions with the intent to promote, manage, establish, carry on, and facilitate the promotion, management, establishment, and carrying on of criminal activity, to wit: ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: 1810 1. 12 13 14 15 16 a7 18 19 20 ai 22 23 24 25 26 27 28 COUNT 26: FACILITATING MONEY LAUNDERING PC.186.10(a) (1) On or about December 24, 2019 - January 6, 2020, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of FACILITATING MONEY LAUNDERING, in violation of Section 186.10(a) (1) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding twenty five thousand dollars ($25,000.00), to wit: $213,221.52, through one or more financial institutions with the intent to promote, manage, establish, carry on, and facilitate the promotion, management, establishment, and carrying on of criminal activity, to ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: COUNT 27: FACILITATING MONEY LAUNDERING PC.186.10(a) (1) On or about January 14, 2020, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of FACILITATING MONEY LAUNDERING, in violation of Section 186.10(a) (1) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding twenty five thousand dollars ($25,000.00), to wit: $25,214.00, through one or more 1922 23 24 25 26 aT 28 financial institutions with the intent to promote, manage establish, carry on, and facilitate the promotion, management establishment, and carrying on of criminal activity, to wit: ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: COUNT 28: MONEY LAUNDERING OF PROCEEDS PC.186.10(a) (2) On or about January 28, 2020 - February 13, 2020, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of MONEY LAUNDERING OF PROCEEDS, in violation of Section 186.10(a) (2) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding twenty-five thousand dollars ($25,000.00), to wit: $30,626.69, through one or more financial institutions knowing that the monetary instrument represented the proceeds of, and was derived directly or indirectly from the proceeds of, criminal activity, to wit: ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: 20a ue wn 10 1 12 13 14 15 16 18 19 20 21 22 23 24 25 26 27 28 COUNT 29: FACILITATING MONEY LAUNDERING PC.186.10(a) (1) On or about February 18, 2020, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of FACILITATING MONEY LAUNDERING, in violation of Section 186.10(a) (1) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt t conduct a transaction involving a monetary instrument or instruments of a value exceeding twenty five thousand dollars ($25,000.00), to wit: $35,713.80, through one or more financial institutions with the intent to promote, manage, establish, carry on, and facilitate the promotion, management, establishment, and carrying on of criminal activity, to wit: ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: count 3) FACILITATING MONEY LAUNDERING PC.186.10(a) (1) On or about March 16, 2020, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of FACILITATING MONEY LAUNDERING, in violation of Section 186.10(a) (1) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding five thousand dollars ($5,000.00), to wit: $13,550.00, through one or more financial 2110 11 12 13 14 15 16 17 18 19 20 21 22) 23 24 25 26 27 28 institutions with the intent to promote, manage, establish, carry on, and facilitate the promotion, management, establishment, and carrying on of criminal activity, to wit: ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: COUNT 31: FACILITATING MONEY LAUNDERING PC.186.10(a) (1) On or about March 31, 2020 - April 20, 2020, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of FACILITATING MONEY LAUNDERING, in violation of Section 186.10(a) (1) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding twenty five thousand dollars ($25,000.00), to wit: $46,603.80 through one or more financial institutions with the intent to promote, manage, establish, carry on, and facilitate the promotion, management, establishment, and carrying on of criminal activity, to wit: ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: 210 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 COUNT 32: FACILITATING MONEY LAUNDERING PC.186.10(a) (1) On or about April 23, 2020 - May 6, 2020, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of FACILITATING MONEY LAUNDERING, in violation of Section 186.10 (a) (1) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding twenty five thousand dollars ($25,000.00), to wit: $47,003.80, through one or more financial institutions with the intent to promote, manage, establish, carry on, and facilitate the promotion, management, establishment, and carrying on of criminal activity, to wit: ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: count 3: : FACILITATING MONEY LAUNDERING PC.186.10(a) (1) On or about May 8, 2020 - May 20, 2020, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of FACILITATING MONEY LAUNDERING, in violation of Section 186.10(a) (1) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding 2B10 11 12 13 14 15 16 18 19 20 21 22 23 24 25 26 27 28 twenty five thousand dollars ($25,000.00), to wit: $52,305.00, through one or more financial institutions with the intent to promote, manage, establish, carry on, and facilitate the promotion, management, establishment, and carrying on of criminal activity, to ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: COUNT 34: FACILITATING MONEY LAUNDERING PC.186.10(a) (1) On or about June 1, 2020 - June 29, 2020, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of FACILITATING MONEY LAUNDERING, in violation of Section 186.10(a) (1) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding twenty five thousand dollars ($25,000.00), to wit: $107,057.60, through one or more financial institutions with the intent to promote, manage, establish, carry on, and facilitate the promotion, management, establishment, and carrying on of criminal activity, to wit: ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a. " W " 4wv 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 28 For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s. above, complainant further complains and says COUNT 35: MONEY LAUNDERING OF PROCEEDS PC.186.10(a) (2) On or about July 1, 2020 - July 13, 2020, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of MONEY LAUNDERING OF PROCEEDS, in violation of Section 186.10(a) (2) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding twenty-five thousand dollars ($25,000.00), to wit: $25,500.00, through one or more financial institutions knowing that the monetary instrument represented the proceeds of, and was derived directly or indirectly from the proceeds of, criminal activity, to wit: ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says COUNT 36: FACILITATING MONEY LAUNDERING PC.186.10(a) (1) On or about July 13, 2020, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of FACILITATING MONEY LAUNDERING in violation of Section 186.10(a) (1) of the Penal Code, a FELONY, in 2810 11 12 13 14 15 16 7 18 19 20 21 22 23 24 25 26 27 28 that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding twenty five thousand dollars ($25,000.00), to wit: $30,100.00, through one or more financial institutions with the intent to promote, manage, establish, carry on, and facilitate the promotion, management, establishment, and carrying on of criminal activity, to wit: ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says COUNT 37: FACILITATING MONEY LAUNDERING PC.186.10(a) (1) On or about duly 15, 2020 - July 24, 2020, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of FACILITATING MONEY LAUNDERING, in violation of Section 186.10(a) (1) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding twenty five thousand dollars ($25,000.00), to wit: $55,000.00, through one or more financial institutions with the intent to promote, manage, establish, carry on, and facilitate the promotion, management, establishment, and carrying on of criminal activity, to 2610 qt 12 13 14 15 16 a 18 19 20 21 22 23 24 25 26 27 28 ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: COUNT 38: FACILITATING MONEY LAUNDERING PC.186.10(a) (1) On or about July 28, 2020 - August 24, 2020, in the County of san Joaquin, California, SHAKIR KHAN, did commit the crime of FACILITATING MONEY LAUNDERING, in violation of Section 186.10(a) (1) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding twenty five thousand dollars ($25,000.00), to wit: $66,795.00, through one or more financial institutions with the intent to Promote, manage, establish, carry on, and facilitate the promotion, management, establishment, and carrying on of criminal activity, to wit: ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a, AND EDD FRAUD IN VIOLATION OF UNEMPLOYMENT INSURANCE CODE 2101(a) (1). For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: Ww W 2710 ql 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 COUNT 39: FACILITATING MONEY LAUNDERING PC.186.10(a) (1) On or about August 27, 2020 - September 24, 2020, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of FACILITATING MONEY LAUNDERING, in violation of Section 186.10(a) (1) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding twenty five thousand dollars ($25,000.00), to wit: $130,380.00, through one or more financial institutions with the intent to promote, manage, establish, carry on, and facilitate the promotion, management, establishment, and carrying on of criminal activity, to wi : ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a, AND EDD FRAUD IN VIOLATION OF UNEMPLOYMENT INSURANCE CODE 2101(a) (1). For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: COUNT 40: FACILITATING MONEY LAUNDERING PC.186.10(a) (1) On or about September 25, 2020 - October 20, 2020, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of FACILITATING MONEY LAUNDERING, in violation of Section 186.10(a) (1) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding 2810 11 12 13 14 15 16 a7 18 19 20 21 22 23 24 25 26 27 28 twenty five thousand dollars ($25,000.00), to wit: $68,363.80 through one or more financial institutions with the intent to promote, manage, establish, carry on, and facilitate the promotion, management, establishment, and carrying on of criminal activity, to wit: ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a, , AND EDD FRAUD IN VIOLATION OF UNEMPLOYMENT INSURANCE CODE 2101(a) (1). For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: COUNT 41: FACILITATING MONEY LAUNDERING PC.186.10(a) (1) On or about October 21, 2020 - October 27, 2020, in the County of San Joaquin, California, SHAKIR KHAN, did commit the crime of FACILITATING MONEY LAUNDERING, in violation of Section 186.10(a) (1) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding twenty five thousand dollars ($25,000.00), to wit: $27,545.00, through one or more financial institutions with the intent to promote, manage, establish, carry on, and facilitate the promotion, management, establishment, and carrying on of criminal activity, to wit: ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a " " 29For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: COUNT 42: MONEY LAUNDERING OF PROCEEDS PC.186.10(a) (2) On or about April 6, 2020 - April 13, 2020, in the County of San Joaquin, California, ZAKIR KHAN, did commit the crime of MONEY LAUNDERING OF PROCEEDS, in violation of Section 186.10(a) (2) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding five thousand dollars ($5,000.00), to wit: $13,185.51, through one or more financial inst. tions knowing that the monetary instrument represented the proceeds of, and was derived directly or indirectly from the proceeds of, criminal activity, to wit: ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: COUNT 43: MONEY LAUNDERING OF PROCEEDS PC.186.10(a) (2) On or about April 17, 2020 - May 12, 2020, in the County of San Joaquin, California, ZAKIR KHAN, did commit the crime of MONEY LAUNDERING OF PROCEEDS, in violation of Section 186.10(a)(2) of the 30wv 10 ql 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding twenty-five thousand dollars ($25,000.00), to wit: $34,425.92, through one or more financial institutions knowing that the monetary instrument represented the proceeds of, and was derived directly or indirectly from the proceeds of, criminal activity, to wit: ILLEGAL GAMBLING IN VIOLATION OF PENAL CODE 337a. For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: COUNT 44: MONEY LAUNDERING OF PROCEEDS PC.186.10(a) (2) On or about May 14, 2020 - June 11, 2020, in the County of San Joaquin, California, ZAKIR KHAN, did commit the crime of MONEY LAUNDERING OF PROCEEDS, in violation of Se on 186.10(a) (2) of the Penal Code, a FELONY, in that said defendant did willfully and unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding twenty-five thousand dollars ($25,000.00), to wit: $66,254.13, through one or more financial institutions knowing that the monetary instrument represented the proceeds of, and was derived directly or indirectly from the proceeds of, criminal activity, to wit: ILLEGAL GAMBLING IN