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27 GEORGE GASCON
District Attorney, Los Angeles County
Senior Investigator Jason Convento
Bureau of Investigation
Public Integrity Division
211 W. Temple Street #300
Los Angeles, CA 90012
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
the Matter of the Request for Arrest
arrant filed for the following,
EJANDRO "ALEX" ROJAS
)B: 12/25/1972)
UIS DIAZ ROJAS
)OB: 11/14/1964)
ubmiited by:
enior Investigator Jason Convento
� GOOD CAUSE APPEARING:
CASE NO. BA507932
(Proposed) ORDER TO DISCLOSE
SUBPOENAED GRAND JURY RECORDS
AND TESTIMONY TO DEFENSE
ATTORNEYS IN BA507932
PROTECTIVE ORDER
IT IS HEREBY ORDERED that the People shall make all relevant evidence, including relevant grand jury evidence obtained in grand jury case numbers GJ 19-20/30 and GJ20-21 /034 in their possession and control, available to the defendants' attorneys of record in case BA507932, subject to all protective orders issued by any judicial officer of the Los Angeles Superior Court.
IT IS FURTHER ORDERED that defense counsel of record in this case, their investigators, assistants, and employees (collectively, "the defense team") may review with the defendant, and persons necessary to the preparation and presentation of the defense case, all discovery materials produced by the People pursuant to this order, but shall not provide those persons with copies of, or permit them to make copies of, the discovery unless the discovery is 1 :l
(
Proposed) Protective Order
N
(Proposed) ORDER TO DISCLOSE
SUBPOENAED GRAND JURY RECORDS
AND TESTIMONY TO DEFENSE
ATTORNEYS IN BA507932
PROTECTIVE ORDER
IT IS HEREBY ORDERED that the People shall make all relevant evidence, including relevant grand jury evidence obtained in grand jury case numbers GJ 19-20/30 and GJ20-21 /034 in their possession and control, available to the defendants' attorneys of record in case BA507932, subject to all protective orders issued by any judicial officer of the Los Angeles Superior Court.
IT IS FURTHER ORDERED that defense counsel of record in this case, their investigators, assistants, and employees (collectively, "the defense team") may review with the defendant, and persons necessary to the preparation and presentation of the defense case, all discovery materials produced by the People pursuant to this order, but shall not provide those persons with copies of, or permit them to make copies of, the discovery unless the discovery is 1 :l
(
Proposed) Protective Order
a V.
1 2
3 4
5 6
7 8.
9 t0
11 12
13 14
15 16
17 18
19 20
21 22
23 24
25 26
27 28
redacted to obscure or remove the personal information of third parties, including home and work addresses, and bank account and social security numbers. The attorneys shall also be bound by the discovery provisions of Penal Code section 1054 et al.
IT IS FURTHER ORDERED THAT:
1. As used herein, "protected documents" shall include all writings. audio recordings, photos, and videotapes produced in discovery regardless of the way the item of discovery is produced and/or delivered.
2. The defendants' and their defense teams' use of the protected documents provided pursuant to this court order and the information contained therein is limited to the criminal matter in BA507932. The protected documents and any information contained therein shall not be used by any defendant or his defense team, or any other individual acting on behalf of a defendant, in any other criminal or civil proceeding.
3. Under no circumstances shall the "protected documents," or the inf�}rmation contained therein, be used, retained, compiled, stored, used as a data base, or disseminated in any form by a defendant or his defense team, except for purposes of this criminal matter and in accordance with this Protective Order or by further order of any Los Angeles County Superior Court Judge.
5. Each defendant's attorney shall advise those individuals to whom disclosure is made in accordance with this Protective Order of its contents and their obligations to abide by the terms of this order.
6. If the protected information is included in any motion, application, or othec• court document, said motion, application or court document must be submitted under seal.
I; /
2 (Proposed} Protective Order
i
2 3
4 5
6 7
8 9
10 11
12 13
14 15
16 17
18 19
20 21
22 23
24 25
26 27
28 II.
7. Provisions of this Order, insofar as they restrict disclosure and the use of the protected documents, shall be in effect until further order of any Los Angeles Superior Court Judge,
IT IS SO ORDERED.
Date. tlUl tl 04
tiwe %VWW%W4P. F0�1'��
o
�.: `©'s Angeles
.�' 01..
08,. L;. 000 0. '
s k My
3 (Proposed) Protective Order
io%'�ourt Judge
:,
GEORGE GASCON
District Attorney, Los Angeles County
Senior Investigator Jason Convento
Bureau of Investigation
Public Integrity Division
211 W. Temple Street #300
Los Angeles, CA 90012
SUPERIOR COURT OF THE STATE OF CALIFORNIA
FOR THE COUNTY OF LOS ANGELES
In the Matter of the Request for Arrest Warrant
filed for the following:
ALEJANDRO "ALEX" ROJAS
(DOB: 12/25/1972)
LUIS DIAZ ROJAS
(DOB: 11/14/1964)
Submitted by:
Senior Investigator Jason Convento
Declaration of Senior Investigator
Jason Convento;
Request for Orders and
Order Sealing Request for Arrest
Warrant
DECLARATION OF SENIOR INVESTIGATOR JASON CONVENTO
1. I am a Los Angeles County District Attorney Senior Investigator. I am the affiant in the request for arrest warrant described above. I am familiar with the details of the investigation and the crimes described in the affidavit for the request for arrest warrant.
2. The Los Angeles County Supervising Criminal Court Judge issued an order releasing evidence and information (including subpoenaed records and testimony) obtained in grand jury investigation numbers GJ20-21/03 and GJ 19-20/30 to the Los Angeles County District Attorney's Office (LADA) through its Bureau of Investigation (BOI) for its use in a criminal investigation related to or arising out of the grand jury investigation. The order also allowed the and j
grury evidence to be used in any affidavit submitted to the court to secure a search or arrest 1 Declaration, Request for Order, Order Sealing Request for Arrest Warrant
warrant, provided the request was submitted to the grand jury supervising judge, or his/her designee, under seat. The court order further provided that evidence released pursuant to the court ordVr is subject to the rule of grand jury secrecy and is not to be disseminated to other parties, including members of the public, without prior authorization of the court. The orders are dated Apri122, 2020, January 1 1, 2021, and May 27, 2021.
3. Information learned from the released grand jury evidence and during the LADA-BOI criminal investigation is contained in the Complaint for Arrest Warrant, the Affidavits in Support thereof, and all supporting attachments.
Based upon the foregoing, I hereby request that the Complaint for Arrest Warrant and all supporting documents incorporated thereto (filing packet) be sealed and kept in the custody of the Los Angeles County Clerk and not be made public until both defendants have appeared before the court in connection with the Complaint for Arrest Warrant issued in BA507932 or until further order by any Los Angeles County Superior Court Judge.
I declare under penalty of perjury, under the laws of the State of California, the foregoing to be true and correct, and that this declaration was executed at Los Angeles, California.
DATED: 8/9/2022
Signature of Affiant
JASON CONVENTO, Senior Investigator
Los Angeles County District Attorney's Office
Bureau of Investigation
Public Integrity Division
2 Declaration, Request for Order, Order Sealing Request for Arrest Warrant
URDER OF THE CQURT
Based upon the foregoing affidavit and a reading of the Complaint for Arrest Warrant, the Affidavit in Support thereof, and all supporting attachments, it is hereby ordered that the request For Criminal Complaint for Arrest Warrant, the Affidavit in Support thereof, and all attachments (filing packet), be sealed and be kept in the custody of the Los Angeles County Clerk and not be made a public record until both defendants have appeared before the court in connection with the Complaint for Arrest Warrant issued in BA507932 or until further order by any Los Angeles County Superior Court Judge.
DATED:
Signature of Magistrate
Judge of the Superior Court, Judicial District
3 Declaration, Request for Order, Qrder Sealing Request for Arrest Warrant
SUPEIdIOR COURT OF THE STATE OF CALIFOKNIA
ICOR TIIE COUNTY Or L,OS ANGELES
THE PEOPLE Oh THC STATE OF CALIFORNIA,
Plaintiff,
v.
O1 ALEJANDRO JESUS ROJAS (DOI3: 12/2/1972),
aka ��LEX ROJAS, and
02 [..UIS DIA7� ROJAS (DOB: 11/14/1964)
The undersigned is in(��rm�ci alld believes that:
Defendant(s).
COUNT 1
CASE NO. BASU7932
F'EL ON 1' COMPLAINT
FOR ,�iRREST WARRANT
SP��CIALLY ASSIGIi"!ED DDA:
1.....� _ �_� . .
OIl 01' between April 21, 201 S and January 23, 2017, in the County of Los Angeles, the crime of SOLICITING A BRIBE, IIl Vlolat1011 Of• PENAL CODE SECTION 68, a Felony, was committed by ALEJANDRO JESUS ROJAS and LUIS DIAZ ROJAS, who asked, received, and agreed to receive, a bribe, upon an agreement of understanding that the defendant's vote, opinion, or action upon a matter then pending, or which might have been brought before the defendant in his official capacity as Superintendent of Bassett United School District, shall have been influenced thereby.
NOTICE: Upon a felony conviction for the above offense, prison custody time is to be served in state prison pursuant to Penal Code section 1170.
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FELONY COMPLAINT FOR ARREST WARRANT
Case No. BA507932
coUNT 2
On or about May 27, 2015, in the County of Los Angeles, the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186,10(a), a Felony, was committed by ALEJANDRO JESUS ROJAS and LUIS DIAZ ROJAS, who did unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding $5,000 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: conspiracy in soliciting and accepting bribes, and knowing that the monetary instrument represented the proceeds of, and was derived directly or indirectly from the proceeds of, criminal activity.
COUNT 3
On or about June 16, 2015, in the County of Los Angeles, the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a Felony, was committed by ALEJANDRO JESUS ROJAS and LUIS DIAZ ROJAS, who did unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding $5,000 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: conspiracy in soliciting and accepting bribes, 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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EAKEBW1
On or about July 14,5, in the County of Los Angeles, the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 18b.10(a), a Felony, was committed by ALEJANDRO JESUS ROJAS and LUIS DIAZ ROJAS, who did unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding $5,000 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: conspiracy in soliciting and accepting bribes, and knowing that the monetary instrument represented the proceeds of, and was derived directly or indirectly from the proceeds of, criminal activity.
COUNT 5
On or about August 22, 2015, in the County of Los Angeles, the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION' 186
.10(a), a Felony, was committed by ALEJANDRO JESUS
ROJAS and LUIS DIAZ ROJAS, who did unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding $5,000 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: conspiracy in soliciting and accepting bribes, 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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FELONY COMPLAINT FOR ARREST WARRANT
COUNT 6
On or about December 13, 20154j in the County of Los Angeles, the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a Felony, was committed by ALEJANDRO JESUS ROJAS and LUIS DIAZ ROJAS, who did unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding $5,000 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: conspiracy in soliciting and accepting bribes, and knowing that the monetary instrument represented the proceeds of, and was derived directly or indirectly from the proceeds of, criminal activity.
COUNT 7
On or about January 4, 2016, in the County of Los Angeles, the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a Felony, was committed by ALEJANDRO JESUS ROJAS and LUIS DIAZ ROJAS, who did unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding $5,000 through a financial institution with the intent to promote, manage, establish, carr
y on, and facilitate the promotion, management, establishment, and carrying on of criminal activity, to wit: conspiracy in soliciting and accepting bribes, 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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FELONY COMPLAINT FOR ARREST WARRANT
COUNT 8
On or about July 25, 2016, in the County of Los Angeles, the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a}, a Felony, was committed by ALEJANDRO JESUS ROJAS and LUIS DIAZ ROJAS, who did unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding $5,000 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. conspiracy in soliciting and accepting bribes, and knowing that the monetary instrument represented the proceeds of, and was derived directly or indirectly from the proceeds of, criminal activity.
COUNT 9
On or about August 5, 2016, in the County of Los Angeles, the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a Felony, was committed by ALEJANDRO JESUS ROJAS and LUIS DIAZ ROJAS, who did unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding $5,000 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: conspiracy in soliciting and accepting bribes, and knowing that the monetary instrument represented the proceeds of, and was derived directly or indirectly from the proceeds of, criminal activity.
Rev. 920-05!20 DA Case 42865376 Page 5 Case No. BA507932
FELONY COMPLAINT FOR ARREST WARRANT
COUNT 10
On or about December 18, 2016, in the County of Los Angeles, the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a Felony, was committed by ALEJANDRO JESUS ROJAS and LUIS DIAZ ROJAS, who did unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding $5,000 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: conspiracy in soliciting and accepting bribes, and knowing that the monetary instrument represented the proceeds of, and was derived directly or indirectly from the proceeds of, criminal activity.
COUNT 11
On or about December 22, 2016, in the County of Los Angeles, the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a Felony, was committed by ALEJANDRO JESUS ROJAS and LUIS DIAZ ROJAS, who did unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding $5,000 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: conspiracy in soliciting and accepting bribes, and knowing that the monetary instrument represented the proceeds of, and was derived directly or indirectly from the proceeds of, criminal activity.
Rev. 920-05!20 DA Case 42865376 Page 6 Case No. BA507932
FELONY COMPLAINT FOR ARREST WARRANT
COUNT 12
On or about January 12, 2017, in the County of Los Angeles, the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a Felony, was committed by ALEJANDRO JESUS ROJAS and LUIS DIAZ ROJAS, who did unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding $5,000 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: conspiracy in soliciting and accepting bribes, and knowing that the monetary instrument represented the proceeds of, and was derived directly or indirectly from the proceeds of, criminal activity.
COUNT 13
On or about January 23, 2017, in the County of Los Angeles, the crime of MONEY LAUNDERING, in violation of PENAL CODE SECTION 186.10(a), a Felony, was committed by ALEJANDRO JESUS ROJAS and LUIS DIAZ ROJAS, who did unlawfully conduct and attempt to conduct a transaction involving a monetary instrument or instruments of a value exceeding $5,000 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. conspiracy in soliciting and accepting bribes, and knowing that the monetary instrument represented the proceeds of, and was derived directly or indirectly from the proceeds of, criminal activity.
Furthermore, as to counts} 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12 and 13 the value of the transactions resulted in the loss of more than one hundred fifty thousand dollars {$150,000), and thus subjecting ALEJANDRO ROJAS AND ALEX ROJAS to the additional punishment provided for in Penal Code section 186.10(c)(1)(B).
NOTICE: Prison custody time is to be served in state prison if the enhancement pursuant to Penal Code section 186.11 is imposed as part of the sentence for the above offense, within the meaning of Penal Code section I I70(h)(3).
Rev. 920-05/20 DA Case 428fi537fi Page 7 Case No. BA507932
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COUNT 14
On or about April 21, 2015, in the County of Los Angeles, the crime of HAVING A FINANCIAL INTEREST IN A CONTRACT, in violation of GOVERNMENT CODE SECTION 1090 was committed by ALEJANDRO JESUS ROJAS, who did, while Superintendent of the Bassett Unified School District, become financially interested in a contract, to wit, a construction services contract with Del Terra Group valued at $30,000,000.00, made by him in his official capacity, and by a body and board of which the defendant ALEJANDRO JESUS ROJAS, was a member.
COUNT I S
On or about March 8, 20 i 6, in the County of Los Angeles, the crime of PERJURY BY DECLARATION, in violation of PENAL CODE SECTION i l 8(a), a Felony, was committed by ALEJANDRO JESUS ROJAS, who did unlawfully, under penalty of perjury, declare as true, that which was known to be false, to wit: his source and amount of outside income in his Form 700, Statement of Economic Interests,
COUNT 16
On or about March 13, 2017, in the County of Los Angeles, the crime of PERJURY BY DECLARATION, in violation of PENAL CODE SECTION 118(a), a Felony, was committed by ALEJANDRO JESUS ROJAS, who did unlawfully, under penalty of perjury, declare as true, that which was known to be false, to wit: his source and amount of outside income in his Form 700, Statement of Economic Interests.
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M
On or about March 20, 201$, in the County %J Los Angeles, the crime of PERJURY BY DECLARATION, in violation of PENAL CODE SECTION 118(a), a Felony, was committed by ALEJANDRO JESUS ROJAS, who did unlawfully, under penalty of perjury, declare as true, that which was known to be false, to wit: his source and amount of outside income in his Form 700, Statement of Economic Interests.
It is further al leged as to counts) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13, 14, 15, 16 and 17, that the said offenses are described in Penal Code section iil that the above violations were not discovered and could not reasonably have been discovered until after March 5, 2019, and that no victim of said violations and no law enforcement agency chargeable with the investigation and prosecution of said violation had actual and constructive knowledge of said violations prior to said date of March 5, 2019, within the meaning of Penal Code section 803(c).
In February 2018, the Los Angeles County Office of Education (LACOE) contacted Bassett Unified School District (District) Superintendent Deborah French and informed her of suspect business practices used by District -contractor Del Terra Group (Del Terra). LACOE, concerned that Del Terra may have committed financial fraud in its dealings with other school districts, asked French to conduct an inquiry into Del Terra's business practices in the District. French assigned the inquiry to the Law Offices of Leal and Trejo ("Law )
ffice"), the District's legal counsel.
On March 5, 2019, the Law Office issued amulti-page report ("Report") with exhibits citing numerous Del Terra billing irr
egularities, including over one million dollars in unsubstantiated charges.
The Report found that on Apr0
121, 2015, the District Board of Education (Board) signed a construction services contract (Contract) with Del Terr a for construction management (CM) and program
management (PM) services related to Measure "V," a November 2014 $30 million voter -approved bond program.
The Report further found that the Contract was negotiated by then District Superintendent Dr.
Alejandro "Alex" Rojas (Defendant 1) and Del Terra Chief Executive Officer Luis Diaz Rojas (Defendant 2).
The two defendants are not related. According to the Report, Defendant 1 submitted the Contract to the Board For approval but did not include the Law Office in its drafting.
On April 21, 2015, the Board approved the Contract. Attached to the Contract was Exhibit C, which Rev. 920-05/20 DA Case 42865376 Page 9 Case No. BA507932
FELONY COMPLAINT FOR ARREST WARRANT
provided that Del Terra would be compensated for "Additional Services" that were in addition to CM or PM authorized expenses.
The Report highlighted several Del Terra invoices related to the "Additional Services" that merited further attention. The invoices, dated between April 29, 2015 and September 15, 2016, were alt signed and approved by Alex and paid by the District (through LACOE). The payments, totaling $1,037,750, were for work the Report's authors could not substantiate. When asked to provide supporting documentation for the invoices, Defendant 1, who resigned his position as superintendent on May 23, 2017 for unknown reasons, told the authors of the Report that all relevant documents were in his former office in the District. Defendant 2 did not respond to requests for documents.
During the District/Law Office investigation, Del Terra's business dealings involving the Montebello Unified Schoo! District (MUSD) were under review by the District Attorney's Office. Del Terra's business dealings with Montebello Unified School District (MUSD) were also reviewed during an A.B. 139 extraordinary audit of the MUSD by the Fiscal Crisis &Management Assistance Team (FCMAT). FCMAT published a report of its findings on October 1 1, 2018 (Los Angeles Cocmty Ofrce of Edtrcativn, E�travrdincrry A�rdit oJ'thcMvntehello Unified Schvvl District, Octvher I1, 2418.) The report referenced the Del Terra /MUSD business dealings. In July 2019, during the MUSD investigation, a Fair Political Practices Commission (FPPC) investigation into suspected campaign money laundering by Defendant 2, involving an MUSD board member, came to light. Through a grand jury investigation, FPPC and bank records were subpoenaed for accounts held by entities owned by Defendant 2 and his sister, Virginia Campos—Del Terra Real Estate Services (a subsidiary of Del Terra Group), Sola Property Investments, and Alliances Services Group. An examination of these records revealed that between May 27, 2015 and January 23, 2017, while Defendant 1 was District Superintendent, Sola Properties and Alliance Services Group issued checks totaling over $400,000 to Erudio Technology Solutions ("Erudio") for consulting fees. The checks were deposited into an Erudio bank account held by Defendant 1. Based on a thorough review of the bank records, the Del Terra Real Estate Services account proved to be the source of Erudio's funding. Secretary of State records identified Defendant 1 as the manager/owner of Erudio. According to records provided by the District in response to a Public Records Act request, Defendant 1 failed to disclose this income on his annual Statement of Economic Interests ("Form 700") for the years 2015-2017.
Therefore, based on the above, the offenses, specifically Counts 1-17, with which the defendants are now charged were not discovered and could not reasonably have been discovered until after March 5, 2019, the date of the Law Office's Report to the District.
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COUNT 18
On or between April 29, 2015 and September i 5, 2016, in the County %J Los Angeles, the crime of GRAND THEFT BY EMBEZZLEMENT OF PUBLIC FUNDS, in violation of PENAL CODE SECTION 514, a Felony, was committed by ALEJANDRO JESUS ROJAS and LUIS DIAZ ROJAS, who fraudulently appropriated public funds exceeding nine hundred fifty dollars ($950) in value, and/or secreted those funds with a fraudulent intent to appropriate them, while serving as an officer of a city, or a deputy, clerk, or servant of that officer, specifically, as a Superintendent for Bassett Unified School District, to a use or purpose not in the due and lawful execution of his trust, in his possession and/or under his control by virtue of that trust, was an officer of a city, or a deputy, clerk, or servant of that officer, specifically, Superintendent for Bassett School District, and, who fraudulently appropriated to a use or purpose not in the due and lawful execution of that trust, public funds in his possession and/or under his control by virtue of that trust, and/or secreted those funA
s with a fraudulent intent to appropriate them. The funds amounted to $1,037,750.00, thus exceeding nine hundred fifty dollars ($950).
NOTICE: Upon a felony conviction for the above offense, prison custody time is to be served instate prison pursuant to Penal Code section 1170.
Furthermore, as to counts) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 and 18 the offenses alleged are related felonies, a material element of which is fraud and embezzlement, which involved a pattern of related felony conduct, and the pattern of related felony conduct involved the taking of, and resulted in the loss of more than five hundred thousand dollars ($500,000), thus subjecting ALEJANDRO ROJAS AND ALEX RWAS to the additional punishment provided for in Penal Code sections 186.11(a)(2).
NOTICE: Prison custody time is to be served in state prison if the enhancement pursuant to Penal Code section 186.22 is imposed as part of the sentence for the above offense, within the meaning of Penal Code section I I70(h)(3).
Furthermore, as to counts) 1, 2, 3, 4, 5, 6, 7, 8, 9, 10, 11, 12, 13 and 18 the offenses alleged are related felonies, a material element of which is fraud and embezzlement, which involved a pattern of related felony conduct, and the pattern of related felony conduct involved the taking of, and resulted in the loss of more than one hundred thousand dollars ($100,000), thus subjecting ALEJANDRO ROJAS AND ALEX ROJAS to the additional punishment provided for in Penal Code sections 186.11(a)(3).
Rev. 920-05120 DA Case 42865376 Page 11 Case No. BA507932
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NOTICE: Prison custody time is to be served in state prison if the enhancement pursuant to Penal Code section 186.22 is imposed as part of the sentence for the above offense, within the meaning of Penal Code section 1 I70(h)(3).
Rev. 920-05/20 DA Case 42865376 Page 12 Case No. BA507932 FELONY COl11PLAl1YT FOR ARREST WARRANT
NOTICE: Conviction of this offense will require the defendant to provide DNA samples and print impressions pursuant to Penal Code sections 296 and 296.1. Willful refusal to provide the samples and impressions is a crime.
NOTICE: The People of the State of California intend to present evidence and seek jury findings regarding all applicable circumstances in aggravation, pursuant to Pena! Code section 1170(b) and Ct►►r►►i►rghar►► v. California (2007) 549 U.S. 270.
NOTICE: A Suspected Child Abuse Report (SCAR) may have been generated within the meaning of Penal Code §§ 11166 and 11168 involving the charges alleged in this complaint. Dissemination of a SCAR is limited by Penal Code §§ 11167 and 11167.5 and a court order is required for full disclosure of the contents of a SCAR.
NOTICE: Any allegation making a defendant ineligible to serve a state prison sentence in the county jail shall not be subject to dismissal pursuant to Penal Code § 1385.
NOTICE: Conviction of this offense prohibits you from owning, purchasing, receiving, possessing, or having under your custody and control any firearms, and effective January 1, 2018, will require you to complete a Prohibited Persons Relinquishment Form ("PPR") pursuant to Penal Code § 29810.
Rev. 920-05/20 DA Case 42865376 Page 13 Case No. BA507932
FELONY COMPLAINT FOR ARREST WARRANT
Further, attached hereto and incorporated herein are official reports and documents of a law enforcement agency which the undersigned believes establish probable cause for the arrest of defendants} ALEJANDRO JESUS ROJAS and LUIS DIAZ ROJAS for the above -listed crimes. Wherefore, a warrant of arrest is requested for ALEJANDRO JESUS ROJAS and LUIS DIAZ ROJAS.
I DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT AND THAT THIS COMPLAINT, CASE NUMBER BA507932, CONSISTS OF 18 COUNT(S).
Executed at LOS ANGELES, County of Los Angeles on August 9, 2022.
J,�ON CONVENTO
DECLARANT AND COMPLAINANT
..............................................................................................................................................................................
GEORGE GASCbN, DISTRICT ATTORNEY n
AGENCY: LACO D.A.
BUREAU OF
INVESTIGATION
DR NO.: P20-0200
DEFENDANT
ROJAS, ALEJANDRO JESUS
ROJAS, LUIS DIAZ
Rev. 920-05!20 DA Case 42865378
BY:
�.
STEFAN M�AKICH
DEPUTY DISTRICT ATTORNEY
I/O: 3ASON CONVENTO
OPERATOR: CB
CII NO. DOB
12/25/1972
012473764 11 / 14/ 1964
ID NO.: 661690 PHONE : (213} 379-1322
PRELIM. TIME EST.:
BOOKING
NO.
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FELONY COMPLAINT FOR ARREST WARRANT
$ DAY(S)
BAIL
RECOM'D
$100,000
$100,000
CUSTODY
R'TN DATE
Case No. BA507932