Counts in The Indictment of Priscilla Rocha

Electronically Filed 07/18/201412217212 PM
CLERK OF THE COURT IND STEVEN B. WOLFSON

Clark County District Attorney Nevada Bar #001565 JAY P. RAMAN
Chief Deuty District Attorney Nevada ar #10193
200 Lewis Avenue Las Ve as, Nevada 89155-2212 (702) 6 1-2500
Attorney for Plaintiff DISTRICT COURT CLARK COUNTY, NEVADA THE STATE OF NEVADA, Plaintiff,
CASE NO: -vs- DEPT NO: 11
PRISCILLA ROCHA (NEVADA LULAC STATE DIRECTOR AND MEMBER OF THE LULAC NATIONAL BOARD OF
DIRECTORS) , #1374052
JAIME ESPITIA,
DONNIE PLACENCIA,
NDRES MENDOZA, #1596745
JEROME ROCHA, Defendant(s)
STATE OF NEVADA COUNTY OF CLARK

The Defendant(s) above named, PRISCILLA ROCHA (NEVADA LULAC STATE DIRECTOR AND MEMBER OF
THE LULAC NATIONAL BOARD OF DIRECTORS) , JAIME ESPITIA, DONNIE PLACENCIA, ANDRES MENDOZA
and JEROME ROCHA, accused by the Clark County Grand Jury of the crime(s) of THEFT (Category Felony -
NRS 205.0832, 205.08354 55991, 195.020); UNLAWFUL USE OF PUBLIC MONEY (Category Felony NRS
204.020, 195.020); POSSESSION OF STOLEN PROPERTY (Category Felony - NRS 205.275 56057, 195.020);
BURGLARY (Category Felony - NRS 205.060 - 50424), committed at and within the County of Clark, State
of Nevada, on or between October 7, 2005 and March 31, 2014, as follows:

INDICTMENT S

COUNT 1 - THEFT

Defendant Priscilla Rocha (Nevada LULAC State Director and Member of the LULAC National Board of
Directors) (Nevada LULAC State Director and Member of the LULAC National Board of Directors) did on
or between September I, 2011 and November 30, 2011 then and there wilfully, knowingly, feloniously,
and without lawful authority, convert, make an unauthorized transfer of an interest in, or without
authorization control property, 1 having a value of $3,500.00, or more, belonging to CLARK COUNTY
SCHOOL DISTRICT, in the following manner, towit: by having staff purchase twenty (20) Dell Computers
with school district money at a price of $13,600.00, one (1) Apple iPad 64 GB, three (3) Apple iPads 32
GB, one (1) Hitachi projector, one (1) LCD TV 40 1080P, ve (5) Coby CD players, and ve (5) Asus laptops
paid for by Clark County School District money and thereafter taking possession of said property and
without lawful authority transporting the computers to donate them to schools in Ensenada, Mexico.

COUNT 2 - UNLAWFUL USE OF PUBLIC MONEY

Directors) did on or between September 1, 2011 and November 30, 2011 then and there wilfully,
knowingly, feloniously, and without lawful authority, being a pubic officer or other person who has in
her or custody any public money belonging to this state or any county, town, city, district, or municipal
corporation within this state, or to whom any such public money is entrusted for safekeeping or for
transmission to any treasurer or other ofcer, or other person entitled to receive it, who uses any of the
public money for his or her own private purposes, or for any purpose other than one authorized by law,
the amount unlawfully used being $650.00 or more, in the following manner, to wit: in her position of
Director of the AELAS program for the Clark County School District by having staff purchase twenty (20)
Dell Computers with school district money at a price of 1 3,600.00, one 1) Apple iPad 64 GB, three (3)
Apple iPads 32 GB, one (1) Hitachi projector, one (1) LCD TV 40 1080P, ve (5) Coby CD players, and ve
(5) Asus laptops paid for by Clark County School District money and transporting the computers to
donate them to schools in Ensenada, Mexico. W320 351.15.111.13 SBGJI I .DOCX 09 a U1 41 L40 5-1
L11 -P- DJ

COUNT 3 - THEFT

Defendants Priscilla Rocha (Nevada LULAC State Director and Member of the LULAC National Board of
Directors) and Jaime Espitia did on or between September 23, 2013 and December 31, 2013 then and
there wilfully, knowingly, feloniously, and without lawful authority, convert, make an unauthorized
transfer of an interest in, or without authorization control property, having a value of $3,500.00, or
more, belonging to the Clark County School District, in the following manner, to-wit: by Defendant
Priscilla Rocha (Nevada LULAC State Director and Member of the LULAC National Board of Directors)
directing Renee Romero to a submit a request for payment of an out of district consultant Diaz and
submitting other paperwork to substantiate an employee being paid by the name of Cesar Diaz-
Villanueva, and through timesheets representing that Cesar DiazVillanueva worked for the AELAS
program in the Clark County School District when in truth and in fact he did not, where Defendant Jaime
Espitia had convinced Cesar DiazVillanueva to open a bank account for this purpose and Cesar Diaz-
Villanueva receive nominal compensation, Defendants Rocha and Espitias combined actions resulted in
submission to the Clark County School District that Cesar Diaz-Villanueva worked as a tutor for 480
hours between September 10, 2013 and December 31, 2013 which sent payments totaling the amount
of $8,640.00 of Clark County School District Money to a bank account where the signers to the account
were Cesar Diaz- Villanueva and Defendant Jaime Espitia, that money going for the personal gain of
Jaime Espitia, the Defendants being criminally liable under one or more of the following principles of
criminal liability, to-wit: (1) by directly committing this crime as stated; and/or (2) by aidingor abetting in
the commission of this crime, with the intent that this crime be committed by entering into a course of
conduct whereby Defendant Priscilla Rocha (Nevada LULAC State Director and Member of the LULAC
National Board of Directors) "and signed employment paperwork and timesheets which allowed for the
unlawful transfer of money to Defendant Jaime ESpitia which he then used for his own personal benet
and/or (3) pursuant to a conspiracy to commit this crime.


Directors) did on or between September 23, 2013 and December 31, 2013 then and there wilJlly,
knowingly, feloniously, and without lawful authority being a pubic ofcer or other person who has in her
possession, control, or custody any public money 111:3 3BGJI I .DOCX rLHJ 1:3 belonging to this state or
any county, town, city, district, or municipal corporation within this state, or to whom any such public
money is entrusted for safekeeping or for transmission to any treasurer or other ofcer, or other person
entitled to receive it, who uses any of the public money for his or her own private purposes, or for any
purpose other than one authorized by law, the amount unlawfully used being $650.00 or more, in the
following manner, to wit: in her position of Director of the AELAS program for the Clark County School
District Defendant Priscilla Rocha (Nevada LULAC State Director and Member of the LULAC National
Board of Directors) directing Renee Romero to a submit a request for payment of an out of district
consultant Diaz and submitting other paperwork to substantiate an employee being paid by the name
of Cesar DiazVillanueva, and through timesheets representing that Cesar Diaz-Villanueva worked for the
AELAS program in the Clark County School District when in truth and in fact he did not, where Defendant
Jaime Espitia had convinced Cesar Dilaz-Yillanueva to open a bank account for thisrpurposle and Cesar
DiazI Villanueva receive nominal compensation, Defendants. Rocha and Eispitias combined actions
resulted in submission to the Clark County School District that Cesar Diaszillanueva worked as a tutor for
480 hours between September 10, 2013 and December 31, 2013 which sent payments totaling the
amount of $8,640.00 of Clark County School District Money to a bank account where the signers to the
account were Cesar Diaz-Villanueva and Defendant Jaime Espitia, that money going for the personal gain
of Jaime ESpitia, the Defendants being criminally liable under one or more of the following principles of
criminal liability, to-wit: by directly committing this crime as stated; and/or (2) by aiding or abetting in
the commission ofthis crime, with the intent that this crime be committed by entering into a course of
National Board of Directors) signed employment paperwork and timesheets which allowed for the
unlawful transfer of money to Defendant Jaime Espitia which he then used for his own personal benefit
and/or (3) pursuant toa conspiracy totcommit this crime.

COUNT 5 - THEFT

Directors) and Jaime Espitia did on or between January 1, 2014 and March 31, 2014 then and there
wilfully, knowingly, feloniously, and without lawful authority, convert, make an unauthorized transfer of
an interest in, or without authorization control WlilEiGJlilB'tl 3315] I .DDCX Gs-Ln 43- UJ property,
having a value of $3,500.00, or more, belonging to the Clark County School District, in the following
manner, to-wit: by Defendant Priscilla Rocha (Nevada LULAC State Director and Member of the LULAC
National Board of Directors) directing Renee Romero to a submit a request for payment of an out of
district consultant Diaz and submitting other paperwork to substantiate an employee being paid by the
name of Cesar DiazVillanueva, and through timesheets representing that Cesar Diaz-Villanueva worked
for the AELAS program in the Clark County School District when in truth and in fact he did not, where
Defendant Jaime Espitia had convinced Cesar Diaz-Villanueva to open a bank account for this purpose
and Cesar DiazVillanueva receive nominal compensation, Defendants Rocha and Espitias combined
actions resulted in submission to the Clark County School District that Cesar Diaz- Villanueva worked as a
tutor for 256 hours between January 1, 2014 and March 31, 2014 which sent payments totaling the
account were Cesar DiazVillanueva and Jaime Espitia, that money going for the personal gain of
Defendant Jaime Espitia, the Defendants being criminally liable under one or more of the following
principles of criminal liability, .to- 1 wit: (1) by directly committing this crime as stated; andXor (2) by
aiding or abetting in the commission of this crime, with the intent that this crime be committed by
entering into a course of conduct whereby Defendant Priscilla Rocha (Nevada LULAC State Director and
Member of the LULAC National Board of Directors) signed employment paperwork and timesheets
which allowed for the unlawful transfer of money to Defendant Jaime Espitia which he then used for his
own personal benet andfor (3) pursuant to a consPiracy to commit this crime.


Directors) did on or between January 1, 2014 and March 31, 2014 then and there wilJlly, knowingly,
feloniously, and without lawful authority being a pubic officer or other person who has in her
possession, control, or custody any public money belonging to this state or any county, town, city,
district, or municipal corporation within this state, or to whom any such public money is entrusted for
safekeeping or for transmission to any treasurer or other ofcer, or other person entitled to receive it,
who uses any of the public money for his or her own private purposes, or for any purpose other than
one authorized by law, the amount unlawfully used being $650.00 or more, in the following manner, to
wit: in her position of \Dooqmm-bmm Director of the AELAS program for the Clark County School
District Defendant Priscilla Rocha (Nevada LULAC State Director and Member of the LULAC National
Board of Directors) directing Renee Romero to a submit a request for payment of an out of district
consultant Diaz and submitting other paperwork to substantiate an employee being paid by the name
of Cesar DiazVillanueva, and through timesheets representing that Cesar Diaz~ Villanueva worked for
the AELAS program in the Clark County School District when in truth and in fact he did not, where
Defendant Jaime Espitia had convinced Cesar DiazVillanueva to open a bank account for this purpose
and Cesar Diaz-Villanueva receive nominal compensation, Defendants Rocha and ESpitias combined
actions resulted in submission to the Clark County School District that Cesar DiazVillanueva worked as a
tutor for 256 hours between January 1, 2014 and March 31, 2014 which sent payments totaling the
account were Cesar Diaz-Villanueva and Jaime Espitia, that money going for the personal gain of
Defendant Jaime ESpitia, the Defendants being criminally liable under one or more of the following
principles of criminal liability, to-wit: (1) by directly committing this crime as stated; and/or (2) by aiding
or abetting in the commission of this crime, with the intent that this crime be committed by entering
into a course of conduct whereby Defendant Priscilla Rocha (Nevada LULAC State Director and Member
of the LULAC National Board of Directors) signed employment paperwork and timesheets which
allowed for the unlawful transfer of money to Defendant Jaime Espitia which he then used for his own
personal benefit andfor (3) pursuant to a conspiracy to commit this crime.

COUNT 7 - THEFT

Directors) , Donnie Placencia, and Jerome Rocha did on or bemeen Oiitober 7, 2005 and December 3 l,
2005 then and there wilfully-knowingly, feloniously, and without lawJl authority, convert, make an
unauthorized transfer of an interest in, or without authorization control property, having a value of
$2,500.00, or more, belonging to the Clark County School District, in the following manner, to-wit: by
Directors) submitting request for payment for open ended tutorial services for Donnie Placencia and
submitting other paperwork to substantiate an employee being paid by the name of Donnie Placencia
and through timesheets representing that Defendant Donnie Placcncia worked for 13 -L11 the AELAS
program in the Clark County School District when in truth and in fact he did not, where Defendant
had conspired with Defendant Donnie Placencia and Defendant Jerome Rocha to cpen a bank account
for this purpose, Defendants Priscilla Rocha (Nevada LULAC State Director and Member of the LULAC
National Board of Directors) , Defendant Jerome Rocha and Defendant Donnie Placencias combined
actions resulted in submission to the Clark County School District that Placencia worked for the AELAS
program in the Clark County School District when in truth and in fact he did not, and submitting false
time sheets which sent payments in the total amount of $2,900.00 of Clark County School District
Money to a bank account where the signers to the account were Donnie Placencia and Defendant
Jerome Rocha, for the personal gain of Donnie Placencia and Jerome Rocha, without authorization to
make payments to people who did not actually do the represented work, the Defendants being
criminally liable under one or more of the following principles of criminal liability, to-wit: by directly
committing this crime as stated; and/or (2) by aiding or abetting in the commission of this crime, with
the intent that this crime be committed by entering into a course of conduct whereby Defendant
signed employment paperwork and timesheets which allowed for the unlawful transfer of money to
Defendants Jerome Rocha and Donnie Placencia which they then used for his own personal benet
andXor (3) pursuant to a con5piracy to commit this crime.


Directors) did on or between October 7, 2005 and December 31, 2005 then; and there wilfully,
knowingly, feloniously, and without lawful authority being a pubic - ofcer or other person who has in
her possession, control, or custody any public money belonging to this state or any county, town, city,
wit: in I her position of Director of the AELAS program for the Clark County School District Defendant
submitting request for payment for open ended tutorial services 3BGJI I .DDCX rt rt ri rt CID Ch 'Ulfor
Donnie Placencia and submitting other paperwork to substantiate an employee being paid by the name
of Donnie Placencia and through timesheets representing that Defendant Donnie Placencia worked for
Directors) had conspired with Defendant Donnie Placencia and Defendant Jerome Rocha to open a bank
account for this purpose, Defendants Priscilla Rocha (Nevada LULAC State Director and Member of the
LULAC National Board of Directors) , Defendant Jerome Rocha and Defendant Donnie Placencias
combined actions resulted in. submission to the Clark County School District thatPlacencia worked for
the AELAS program in the Clark County School District when in truth and in fact he did not, and
submittin false timesheets which sent payments in the total amount of $2,900.00 of Clark County School
District Money to a bank account where the signers to the account were Donnie Placencia and
Defendant Jerome Rocha, for the personal gain of Donnie Placencia and Jerome Rocha, without
authorization to make payments to people who did not actually do the 1 represented work, the
Defendants being criminally liable under one or more of the following principles of criminal liability, to-
wit: (I) by directly committing this crime as stated; andfor (2) by aiding or abetting in the commission of
this crime, with the intent that this crime be committed by entering into a course of conduct whereby
Directors) signed employment paperwork and timesheets which allowed for the unlawful transfer of
money to Defendants Jerome Rocha and Donnie Placencia which they then used for his own personal
benet andfor (3) pursuant to a conspiracy to commit this crime.

COUNT 9 - THEFT

Directors) , Donnie Placencia, and Jerome Rocha did on or between January 1, 2006 and December 31,
2006 then and there wilfully, knowingly, feloniously, and without lawful authority, convert, make an
unauthorized transfer of an interest in, or without authorization control prOperty, having a value of
and through timesheets representing that Defendant Donnie Placencia worked for .DOCX .00 x1 Ch Ln
'43- RD DD *4 Ch U: 43- the AELAS program in the Clark County School District when in truth and in fact
he did not, where Defendant Priscilla Rocha (Nevada LULAC State Director and Member of the LULAC
National Board of Directors) had conspired with Defendant Donnie Placencia and Defendant Jerome
Rocha to open a bank account for this purpose, Defendants Priscilla Rocha (Nevada LULAC State Director
and Member of the LULAC National Board of Directors) , Defendant Jerome Rocha and Defendant
Donnie Placencias combined actions resulted in 1 submission to the Clark County School District that
Placencia worked for the AELAS program in the Clark County School District when in truth and in fact he
did not, and submitting false time sheets which sent payments in the total amount of $7,950.00 of Clark
County School District Money to a bank account where the signers to the account were Donnie
Placencia and Defendant Jerome Rocha, for the personal gain of Donnie Placencia and Jerome Rocha,
without authorization to make payments to pe0ple who did not actually do the represented work, the
witz, (1) by directly committing this crime as stated; and/or (2) by aiding or abettingin the commission of
this crime, with the-intent: that this crime he committed by entering into a course of conduct whereby


Directors) did on or between January 1, 2006 and December 31, 2006 then and there wilfully,
knowingly, feloniously, and without lawful authority being a pubic officer or other person who has in her
who uses any of thepublic money for his or her own private purposes, or for any purpose-other than
wit: in her position of Director of the AELAS program for the Clark County School District Defendant
submitting request for payment for open ended tutorial services W520 I JB'tGJl'tl 3H .DOCX Ii Ii ItnI
no DO 4 L~m C: GD 'lJl 4:1- 1-13 C3 for Donnie Placencia and submitting other paperwork to
substantiate an employee being paid by the name of Donnie Placencia and through timesheets
representing that Defendant Donnie Placencia worked for the AELAS program in the Clark County School
District when in truth and in fact he did not, where Defendant Priscilla Rocha (Nevada LULAC State
Director and Member of the LULAC National Board of Directors) had conspired with Defendant Donnie
Placencia and Defendant Jerome Rocha to open a bank account for this purpose, Defendants Priscilla
Rocha (Nevada LULAC State Director and Member of the LULAC National Board of Directors) , Defendant
Jerome Rocha and Defendant Donnie Placencias combined actions resulted in submission to the Clark
County School District that Placencia worked for the AELAS program in the Clark County School District
when in truth and in fact he did not, and submitting false time sheets which sent payments in the total
account were Donnie Placencia and Defendant Jerome Rocha, for the personal gain of Donnie Placencia
and Jerome Rocha, without authorization to make payments to people who did not actually do the
represented work, the Defendants being criminally liable under one or more of the following principles
of criminal liability, to-wit: by directly committing this crime as stated; and/or (2) by aiding or abetting in
the commission of this crime, with the intent that this crime be committed by entering into a course of
unlawful transfer of money to Defendants Jerome Rocha and Donnie Placencia which they then used for
his own personal benet and/or (35 pursuant to a conspiracy .to commit this crime. i i

COUNT 1 1 - THEFT

unauthorized transfer of an interest in, or without authorization control preperty, having a value of
and through timesheets representing that Defendant Donnie Placencia worked for 10 Will] I l'tl JHIJBGJI
DOCK the AELAS program in the Clark County School District when in truth and in fact he did not, where
Directors) had conspired with Defendant Donnie PIacencia and Defendant Jerome Rocha to open a bank
account for this purpose, Defendants Priscilla Rocha (Nevada LULAC State Director and Member of the
combined actions resulted in submission to the Clark County School District that PIacencia worked for
submitting false time sheets which sent payments in the total amount of $9,880.00 of Clark County
School District Money to a bank account where the signers to the account were Donnie PIacencia and
authorization to make payments to people who did not actually do the represented work, the
wit: (1) by directly committing this crime as stated; andfor (2) by aiding or abetting in the commission of
money to Defendants Jerome Rocha and Donnie PIacencia which they then used for his own personal


submitting request for payment for open ended tutorial services 11 LII nF-h- UJ C: MD LJJ for Donnie
Placencia and submitting other paperwork to substantiate an employee being paid by the name of
Donnie Placencia and through timesheets representing that Defendant Donnie Placencia worked for the
had conspired with Defendant Donnie . Placencia and Defendant Jerome Rocha to Open a bank account
criminally liable under one or more of the following principles of criminal liability, to-wit: (1) by this
crime as stated; andfor (2) by aiding or abetting in the commission of this crime, with the intent that this
crime be committed by entering'into a course of conduct whereby Defendant Priscilla Rocha (Nevada
LULAC State Director and Member of the LULAC National Board of Directors) signed employment
paperwork and timesheets which allowed for the unlawful transfer of money to Defendants Jerome
Rocha and Donnie Placencia which they then used for his own personal benefit and!or (3) pursuant to a
conspiracy to commit this crime.

COUNT 13 - THEFT

$2,500.00, or more, belonging to the Clark by Defendant Priscilla Rocha (Nevada LULAC State Director
and Member of the LULAC National Board of Directors) County School District, in the following manner,
to-wit: submitting request for payment for open ended tutorial services for Donnie Placencia land
and through timesheets representing that Defendant Donnie Placencia worked for 12 I .DOCX the AELAS
had conspired with Defendant Donnie Placencia and Defendant Jerome Rocha to open a bank account
Money to ai'bank account where the signers to' the account [were Donnie Placencia and Defendant
Jerome Rocha, for the personal gain of. Donnie Placencia and Jerome Rocha, without authorization to
criminally liable under one or more of the following principles of criminal liability, towit: by directly
Defendants Jerome Rocha and Donnie Placencia which they then used for his own personal benefit


Directors) did on or between January 1, 2008; and December 3 1, 2008 then and there wilfully,
safekeeping or for transmission to any treasurer or other officer, or other person entitled to receive it,
submitting request for payment for cpen ended tutorial services 13 I'tl3tl SBGJ I .DDCX foriDonnie
criminally liable under! one or more of the following principles of criminal liability, to-wit: (I) by directly
signed employment paperwork and timesheets which allowed for the unlawJl transfer of money to

COUNT 15 THEFT

and through timesheets representing that Defendant Donnie Placencia worked for 14 pt nt nI- Ib the
time sheets which sent payments in the total amount of $11,880.00 of ClarkCounty School . District
criminally liable under one or more of the following principles of criminal liability, to-wit: (1) by directly
signed employment paperwork and timeshects which allowed for the unlawful transfer of money to
andfor (3) pursuant to a conspiracy to commit this crime.

COUNT 16 - UNLAWFUL OF PUBLIC MONEY

wit: in her position of Director of the AELAS program for the Clark County School District by Defendant
submitting request for payment for open ended tutorial services 15 W910 I SHIJBGJI DOCK bl rm Il- r--
L11 Gib-D DO U1 LIJ CD for Donnie Placencia and submitting other paperwork to substantiate an
employee being paid by the name of Donnie Placencia and through timesheets representing that
Defendant Donnie Placencia worked for the AELAS program in the Clark County School District when in
truth and in fact he did not, where Defendant Priscilla Rocha (Nevada LULAC State Director and Member
of the LULAC National Board of Directors) had conspired with Defendant Donnie Placencia and
Defendant Jerome Rocha to open a bank account for this purpose, Defendants Priscilla Rocha (Nevada
LULAC State Director and Member of the LULAC National Board of Directors) , Defendant Jerome Rocha
and Defendant Donnie Placencias combined actions resulted in submission to the Clark County School
District that Placencia worked for the AELAS program in the Clark County School District when in truth
and in fact he did not, and submitting false time sheets which sent payments in the total amount of
$11,880.00 of Clark County School District Money to a bank account where the signers to the account
were Donnie Placencia and Defendant Jerome Rocha, for the personal gain of Donnie Placencia and
Jerome Rocha, without authorization to make payments to peOple who did not actually do the
represented work, the Defendants being criminally liable under one or more of the following principles
of criminal liability, to-wit: (1) by directly committing this crime as stated; andfor (2) by aiding or
abetting in the commission of this crime, with the intent that this crime be committed by entering into a
course of conduct whereby Defendant Priscilla Rocha (Nevada LULAC State Director and Member of the
LULAC National Board of Directors) signed employment paperwork and timesheets which allowed for
the unlawil transfer of money to Defendants Jerome Rocha and Donnie Placencia which they then used
for his own personal benet andfor (3) pursuant to a conspiracy to commit this crime.

COUNT 17 - THEFT

2010 then and there wilfully, knowingly, felonious-1y, and without lawful authority, convert, make an
Directors) submitting request for payment for Open ended tutorial services for Donnie Placencia and
and through timesheets representing that Defendant Donnie Placencia worked for 16 the AELAS


possession, control, or custody any public money belonging to this State or any county, town, city,
one authorized by law, the amount unlawfully used being $250.00 for more, in the following manner, to
submitting request for payment for open ended tutorial services 17 EEIJEGJ 1 Ch LID for Donnie
had conspired with Defendant Donnie Placencia and Defendant Jerome Rocha to Open a bank account
criminally liable under one or more of the following principles of criminal liability, towit: (I) by directly
committing this crime as stated; and/or (2) aiding or abetting in the commission of this crime, with the
intent that this crime be committed by entering into a course of conduct whereby Defendant Priscilla
Rocha (Nevada LULAC State Director and Member of the LULAC National Board of Directors) signed
employment paperwork and timesheets which allowed for the unlawful transfer of money to

COUNT 19 - THEFT

Directors) , Donnie Placencia, and Jerome Rocha did on or bettveen January 1, 2011 and December 31,
and through timesheets representing that Defendant Donnie Placencia worked for 18 EBGJI .DUCX the
make payments to peeple who did not actually do the represented work, the Defendants being
committing this crime as stated; andz'or (2) by aiding or abetting in the commission of this crime, with
the intent that this crime be committedby entering into a course of conduct whereby Defendant Priscilla
Rocha (Nevada LULAC State Director and Member of the LULAC National Board of Directors) signed
employment paperwork and timesheets which allowed for the unlawful transfer of money to

Count 20 - UNLAWFUL USE OF PUBLIC MONEY

safekeeping or fortransmission to any treasurer or other ofcer, or other person entitled to receive it,
submitting request for payment for open ended tutorial services 19 11-13 SBGJI T. for Donnie
Jerome Rocha, for the personal gain of Donnie Placencia and . Jerome Rocha, without authorization to
committing this crime as stated; andfor (2) by aiding or abetting in the commission of this crime,
withthe intent that this crime be committed by entering into a course of conduct whereby Defendant
signed employment paperwork and timesheets which allowed for the unlawJl transfer of money to
Defendants Jerome Rocha and Donnie Placencia which- they then used for his own personal benet

COUNT 21 - THEFT

2012 then and there willingly, knowingly, feloniously, and without lawful authority, convert, make an
and through timesheets representing that Defendant Donnie Placencia worked for 20 52__6 27 28 the
committing this crime as stated; andtor (2) by aiding or abetting in the commission of this crime, with
signed employment paperwork and timesheets which allowed for the unlawil transfer of money to


Directors) did on or between January 1, 2012 and December 31, 2012 then and there knowingly,
feloniously, and without lawful authority being a pubic ofcer or other person who has in her possession,
control, or custody any public money belonging to this state or any county, town, city, district, or
municipal corporation within this state, or to whom any such public money is entrusted for safekeeping
or for transmission to any treasurer or other ofcer, or other person entitled to receive it, who uses any
of the public money for his or her own private purposes, or for any purpose other than one authorized
by law-,the amount unlawrlly used being $650.00 or more, in the following manner, to wit: in her
position of Director of the AELAS program for the Clark County School District Defendant Priscilla Rocha
(Nevada LULAC State Director and Member of the LULAC National Board of Directors) submitting
request for payment for open ended tutorial services 21 I .DOCX Mfor Donnie Placeneia and submitting
other paperwork to substantiate an employee being paid by the name of Donnie Placeneia and through
timesheets representing that Defendant Donnie Placeneia worked for the AELAS program in the Clark
County School District when in truth and in fact he did not, where Defendant Priscilla Rocha (Nevada
LULAC State Director and Member of the LULAC National Board of Directors) had conSpired with
Defendant Donnie Placeneia and Defendant Jerome Rocha to cpen a bank account for this purpose,
Directors) , Defendant Jerome Rocha and Defendant Donnie Placeneias combined actions resulted in
submission to the Clark County School District that Placeneia worked for the AELAS program in the Clark
County School District when in truth and in fact he did not, and submitting false time sheets which 5th
payments in the total amount of 55 $21,210.00 of Clark County School District Money to a bank account
where the signers to the account were Donnie Placeneia and Defendant Jerome Rocha, for the personal
gain of Donnie Placeneia and Jerome Rocha, without authorization to make payments to people who did
not actually do the represented work, the Defendants being criminally liable under one or more of the
following principles of criminal liability, to-wit: by crime as stated;-andfor (2) by aiding or abetting in the
commission of this crime, with the intent that this crime be committed by entering into a course of
unlawful transfer of money to . Defendants Jerome Rocha and Donnie Placeneia which they then used
for his own personal benet and/or (3) pursuant to a conspiracy to commit this crime.

COUNT 23 - THEFT

Directors) , Donnie Placeneia, and Jerome Rocha did on or between January 1, 2013 and December 31,
$3,500.00, or more, belonging to the Clark County School District, in the following manner, towit: by
Directors) submitting request for payment for open ended tutorial services for Donnie Placeneia
submitting other paperwork to substantiate an employee being paid by the name of Donnie Placeneia
and through timesheets representing that Defendant Donnie Placeneia worked for 22 qul DUCK rI l-I Il-
pt pt Ib p-d 0O 'H-LIJ the AELAS program in the Clark County School District when in truth and in fact
he did not, where Defendant Priscilla Rocha (Nevada LULAC State Director and Member of the LULAC
National Board of Directors) had conspired with Defendant Donnie Placencia and Defendant Jerome
Rocha to open a bank account for this purpose, Defendants Priscilla Rocha (Nevada LULAC State Director
and Member of the LULAC National Board of Directors) , Defendant Jerome Rocha and Defendant
Donnie Placencias combined actions resulted in submission to the Clark County School District that
Placencia worked for the AELAS program in the Clark County School District when in truth and in fact he
did not, and submitting false timesheets which. sent payments in the total amountof $19,425 .00 of
Clark-County School District Money to a bank account where the signers to the account were Donnie
Placencia and Defendant Jerome Rocha, for the personal gain of Donnie Placencia and Jerome Rocha,
without authorization to make payments to people who did not actually do the represented work, the
wit: by directly committing this crime as stated; and/or (2) by aiding or abetting in the commission of
this crime, with the intent that this crime he committed by entering into a course of conduct whereby
benet and/or (3) pursuant to a conspiracy to commit this crime.


Directors) did on or betweenJanuary 1, 20-13 and December 31, 2013 then and there wilfully,
possession, control, or custody any public money . belonging to this state or any county, town, city,
one authorized by law, the amount unlawully used being $650.00 or more, in the following manner, to
wit: in her position of Director of the AELAS program for the Clark County School District by Defendant
submitting request for payment for open ended tutorial services 23 1.1113301 I ri rt Il- rI rt rt lI. for
Donnie Placencia and submitting other paperwork to substantiate an employee being paid by the name
of Donnie Placencia and through timesheets representing that Defendant Donnie Placencia worked for
Directors) had conspired with Defendant Donnie Placencia and Defendant Jerome Rocha to open a bank
account for this purpose, Defendants . Priscilla Rocha (Nevada LULAC State Director and Member of the
combined actions resulted in submission to the Clark County School District that Placencia worked for
submitting false time sheets which sent payments in the total amount of $19,425.00 of Clark County
School District Money to a bank account where the signers to the account were Donnie Placencia and
authorization to make payments to people who did not actually do the represented work, the
Defendants being criminally liable under one or more of the following principles of criminal liability,-to-
wit: (1) by directly committing this crime as stated; and/or - (2) by aiding or abetting in the commission
of this crime, with the intent that this crime he committed by entering into a course of conduct whereby
benet and/or (3) pursuant to a conspiracy to commit this crime.

COUNT 25 - THEFT

Directors) , Donnie Placencia, and Jerome Rocha did on or between January 1, 2014 and March 31, 2014
then and there wilfully, knowingly, feloniously, and without lawful authority, convert, make an
$3,500.00, or more, belonging to the Clark I County School District, in the following manner, to-wit: by
and through timesheets representing that Defendant Donnie Placencia worked for 24 I the AELAS


Directors) did on or between January 1, 2014 and March 31, 2014 then and-there wilJlly, knowingly,
by law, the amount unlawfully used being $650.00 or more, in the following manner, to wit: in her
position of Director of the AELAS program for the Clark County School District Defendant Priscilla Rocha
(Nevada LULAC State Director and Member of the LULAC National Board of Directors) submitting
request for payment for open ended tutorial services for Donnie Placencia 25 WAIDHEIGJHITH SBGJI I
.DDCX and submitting other paperwork to substantiate an employee being paid by the name of Donnie
Placencia and through timesheets representing that Defendant Donnie Placencia worked for the AELAS
committing this crime as stated; andfor (2) by aiding or abetting in the commission of this crime, with
and/or (3) pursuant to a conSpiracy to commit this crime.

COUNT 27 THEFT

Directors) and Andres Mendoza did on or between November 8, 2011 I and January 1, 2013 then and
there wilfully, knowingly, feloniously, and without lawrl authority, convert, make an unauthorized
transfer of an interest in, or without authorization control property, having a value of $650.00, or more,
belonging to the Clark County School District, in the following manner, to-wit: by Defendant Priscilla
Rocha (Nevada LULAC State Director and Member of the LULAC National Board of Directors) having
Clark County School District employee Manuel Ramirez purchase a Dell computer, four (4) Foscam
security cameras and an Apple iPad 64 GB that cost $2,099.55 and provide and install said items at the
residence and business of Defendant Andres Mendoza, for his personal benet, Defendants 26 EBGJI I
.DOCK Ii mmm-thHehmdmm-PIUJMHG knowing that the items were unlawfully obtained, the
Defendants being criminally liable under one or more of the following principles of criminal liability, tic-
wit: by directly committing this crime as stated; andXor (2) by aiding or abetting in the commission of
Directors) directed Manuel Ramirez to procure and deliver the aforementioned CCSD property to
Defendant Andres Mendoza which he then used for his own personal benet, not for the benet of CCSD

COUNT 28 - POSSESSION OF STOLEN PROPERTY

Defendant Andres Mendoza did on or did on or between November 8, 2011 and January 28, 2014
between wililly, and feloniously, for his own gain, possess stolen property, to wit: a Dell computer, four
(4) Foscam security cameras and an Apple iPad 64 GB that cost $2,099.55 by the Clark County School
District, having a value of $650.00 or more, said Defendant knew it was stolen property and/or did
possess it under_circumstances which would have caused a reasonable person'to know that it was
stolen preperty.

COUNT 29 - BURGLARY

Defendant Andres Mendoza did on January 28, 2014 then and there willfully, unlawfully, and feloniously
enter, with intent to commit a felony or to obtain money under false pretenses, to-wit: by entering that
certain building occupied by EZ PAWN, located at 1501 E. Charleston Ave, Las Vegas,'Clark County,
Nevada with the intent to pawn an IPAD that belonged to the Clark County School District, under the
pretense that he had the right to pawn the item.


Directors) did on or between November 8, 2011 and January 1, 2013 then and there wilfully, knowingly,
feloniously, and without lawul authority being a pubic officer or other personwho has in her possession,
of the public 27' 311113611 1 .DUCX axon-me tacos-J- money for his or her own private purposes, or for
any purpose other than one authorized by law, the amount unlawrlly used being $650 or more, in the
following manner, to wit: in her position of Director of the AELAS program for the Clark County School
District by Defendant Priscilla Rocha (Nevada LULAC State Director and Member of the LULAC National
Board of Directors) having Clark County School District employee Manuel Ramirez purchase a Dell
computer, four (4) Foscam security cameras and an Apple iPad 64 GB that cost $2,099.55 and provide
and install said items at the residence of Defendant Andres Mendoza, for his personal benet,
Defendants knowing that the items were unlawfully obtained, the Defendants - being criminally liable
under one or more of the following principles of criminal liability, to- wit: (1) by directly committing this
crime as stated; and/or (2) by aiding or abetting. in the commission of this crime, with the intent that
this crime be committed by entering into a course of conduct whereby Defendant Priscilla Rocha
(Nevada LULAC State Director and Member of the LULAC National Board of Directors) directed Manuel
Ramirez to procure and deliver the aforementioned CCSD property to Defendant Andres Mendoza which
he then used for his own personal benet, not for the benefit of CCSD and/or (3) pursuant to a
conspiracy to commit this crime.

COUNT 31 THEFT

Directors) did on or between June 6, 2013 to March 19, 2014 then and there wilfully, knowingly,
feloniously, and without lawful authority, convert, make an unauthorized transfer of an interest in, or
without authorization control services, having a value of $650.00, or more, belonging to the Clark
County School District, in the following manner, to-wit; by Defendant Priscilla Rocha (Nevada LULAC
State Director and Member of the LULAC National Board of Directors) without authorization directing
Clark County School District Employee Ana Soto work for Defendant Priscilla Rocha (Nevada LULAC State
Director and Member of the LULAC National Board of Directors) at Yamilex Beauty Salon when it was
represented through time card that Ana Soto was working at the school district as a tutor, yielding
payments from the Clark County School District to Ana Soto for work not actually performed, in the
amount of $2,483.01, the Defendant being criminally liable under one or more of the following
principles of criminal liability, to-wit: (1) by directly committing this crime as stated; andfor (2) by aiding
or abetting in the commission of this crime, with the intent that this crime be committed by entering
into a course of conduct whereby Defendant 28 Wilt} I 33113.1 1 I DOCK Priscilla Rocha (Nevada LULAC
State Director and Member of the LULAC National Board of Directors) directed and encouraged Ana
Soto to work at Yamilex Beauty Salon, which benetied Defendant Priscilla Rocha (Nevada LULAC State
Director and Member of the LULAC National Board of Directors) , not for the benet of CCSD.


Directors) did on or between June 6, 2013 to March 19, 2014 then and there wilJlly, knowingly,
position of Director of the AELAS program for the Clark County School District by Defendant Priscilla
Rocha (Nevada LULAC State Director and Member of the LULAC National Board of Directors) without
authorization having Clark County School District Employee Ana Soto work for Defendant Priscilla Rocha
(Nevada LULAC State Director and Member of the LULAC National Board of Directors) at Yamilex Beauty
Salon when it was represented through time card that Ana Soto was working at the school district as a
tutor, yielding payments from the Clark County School District to Ana Soto for work not actually
performed, in the amount of $2,483.01, the Defendant being criminally liable under one or more of the
following principles of criminal liability, to-wit: (1) by directly committing this crime as stated; and/or (2)
by aiding or abetting in the commission of this crime, with the intent that this crime be committed by
entering into a course of conduct whereby Defendant Priscilla Rocha (Nevada LULAC State Director and
Member of the LULAC National Board of Directors) directed and encouraged Ana Soto to work at
Yamilex Beauty Salon, which benetied Defendant Priscilla Rocha (Nevada LULAC State Director and
Member of the LULAC National Board of Directors) , not for the benet of CCSD.

COUNT 33 - THEFT

Directors) did on or between July 20-, 2010 and March 14, 2014 then and there wilfully, knowingly,
feloniously, and without lawful authority, use the property iof 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, having a value of $3,500.00 or more, belonging to the Clark County School District, in the
following manner, towit: by reouiring 29 WED I 3B'tGJiltl 3361] .oocx Chi. C: No OUR-1 Gs C3 that a
fee be charged to students of the AELAS program for dictionaries that were purchased with CCSD mds,
and that the money collected from the dictionary fees be delivered to Defendant Priscilla Rocha (Nevada
LULAC State Director and Member of the LULAC National Board of Directors) , in cash, in envelopes
without authorization for her own personal gain, the amount of cash Defendant Priscilla Rocha (Nevada
LULAC State Director and Member of the LULAC National Board of Directors) received was $34,590.00.


Directors) did on or betweenJuly 20, 2010 and March 14, 20-14 then and there wilfully, knowingly,
feloniously, and without lawJI authority being a pubic ofcer or other person who has in her possession,
control, or-custody any public money belonging to this state or any county, town, city, district, or
position of Director of the AELAS program for the Clark County School District by requiring that a fee be
charged to students of the AELAS program for dictionaries that were purchased with CCSD funds, and
that the money collected from the dictionary fees be delivered to Defendant Priscilla Rocha (Nevada
LULAC State Director and Member of the LULAC National Board of Directors) , in cash, in envelopes
without authorization; for her own personal gain, the amount of cash Defendant Priscilla Rocha (Nevada
LULAC State Director and Member of the LULAC National Board of Directors) received was $34,590.00.

COUNT 35 THEFT

Directors) did on or between January 1, 2010 and December 3 1, 2010 then and there wilfully,
knowingly, feloniously, and without lawful authority, obtain lawful money of the United States in the
amount of $2,500.00 or more, belonging to the CLARK COUNTY SCHOOL DISTRICT, by a material
misrepresentation with intent to deprive that entity of the property, in the following manner, to-wit: by
directing and authorizing Clark County School District employee Renee Romero to create checks #1154,
1161, 1165, 1169, 1173, 1175, and 1178 from Bank of America account ending in #8801, made payable
to Olveritas Village, 648 N. Main St, Los Angeles, CA, totaling $31,151.00, and then Defendant Priscilla
Rocha (Nevada LULAC State Director and Member of the LULAC National Board of Directors) depositing
the checks into a bank account attributed to Olveritas Tradition 30 SBGJI I .DUCX .pI .bJ ri nn rI rA In
\Docmm-h-mm Folklore, LLC, of which Defendant Priscilla Rocha (Nevada LULAC State Director and
Member of the LULAC National Board of Directors) is sole owner, thereby misrepresenting the recipient
of the money, and using said deposit for her own personal benet without authorization from the Clark
County School District.


wit: in her position of Director of the AELAS program for the Clark County School District by directing
and authorizing Clark County School District employee Renee Romero to create checks #1154, 1161,
1165, 1169, 1173, 1175, and 1178 from Bank ofAmerica account ending in #8 801 which is funded with
Lab fees collected from the students of the AELAS program, i made payable to Olveritas Village, 648 N.
Main St, Los Angeles, CA, totaling $31,151.00, and then Defendant Priscilla Rocha (Nevada LULAC State
Director and Member of the LULAC National Board of Directors) depositing the checks into a bank
account attributed to Olveritas Tradition 85 Folklore, LLC, of which Defendant Priscilla Rocha (Nevada
LULAC State Director and Member of the LULAC National Board of Directors) is sole owner, thereby
misrepresenting the recipient of the money, and using said deposit for her own personal benet without
authorization from the Clark County School District.

COUNT 37 - THEFT

Directors) did on or between January 1, 2011 and December 31, 2011 then and there
wilfully,'knowingly, feloniously, and without lawful authority, obtain lawrl money of the United States in
the amount of $650.00 or more, belonging to the CLARK COUNTY SCHOOL DISTRICT, by a material
directing and authorizing Clark County School District employee Renee Romero to create check #1195
from Bank of America 31 Wl 31113511 I .DDCX account ending in #8801, made payable to Olveritas
Village, 648 N. Main St, Los Angeles, CA, in the amount of $3,000.00, and then Defendant Priscilla Rocha
(Nevada LULAC State Director and Member of the LULAC National Board of Directors) depositing the
check into a bank account attributed to Olveritas Tradition Folklore, LLC, of which Defendant Priscilla
Rocha (Nevada LULAC State Director and Member of the LULAC National Board of Directors) is sole
owner, thereby misrepresenting the recipient of the money, and using said deposit for her own personal
benet without authorization from the Clark County School District.

COUNT 38 UNLAWFUL USE OF PUBLIC MONEY

safekeeping or for transmission to any treasurer or other ofcer, or otherlperson entitled to receive it,
who uses any of the public money for his or her own priyate purposes, or for any purpose other than
one authorizedby law, the amount unlawfully used being $650.00 or more, in the following manner, to
and authorizing Clark County School District employee Renee Romero to create check #1195 from Bank
of America account ending in #8801 which is funded with Lab fees collected from the students of the
AELAS program, made payable to Olveritas Village, 648 N..Main St, Los Angeles, CA, in the amount of
$3,000.00 and then Defendant Priscilla Rocha (Nevada LULAC State Director and Member of the LULAC
National Board of Directors) depositing the check into a bank account attributed to Olveritas Tradition
Folklore, LLC, of which Defendant Priscilla Rocha (Nevada LULAC State Director and Member of the
LULAC National Board of Directors) is sole owner, thereby misrepresenting the recipient of the money,
and using said deposit for her own personal benet without authorization from the Clark County School
District.


Directors) did on or between anuaryl, 201-2-and December 2012 then and there willfully, knowingly,
feloniously, and without lawful authority, obtain lawful money of the United States in the amount of
$3,500.00 or more, belonging to the CLARK 32 scooqotm-b-mm . COUNTY SCHOOL DISTRICT, by a
material misrepresentation with intent to deprive that entity of the property, in the following manner,
towit: by directing and authorizing Clark County School District employee Renee Romero to create
checks #1199, 1201, 1205, 1210, and 1211 from Bank of America account ending in #8801, made
payable to Olveritas Village, 648 N. Main St, Los Angeles, CA, totaling $18,760.00, and then Defendant
depositing the checks into a bank account attributed to Olveritas Tradition Folklore, LLC, of which
Defendant "Priscilla Rocha (Nevada LULAC State Director and Member of the LULAC National Board of
Directors) is sole owner, thereby misrepresenting the recipient of the money, and using said deposit for
her own personal benet without authorization from the Clark County School District.


wit: in her position of Director of the AELAS program for the Clark County School District. by directing
1205, 1210, and 1211 from Bank of America account ending in #8801 which is funded with Lab fees
collected from the students of the AELAS program, made payable to Olveritas Village, 648 N. Main St,
Los Angeles, CA, totaling $18,760.00, and then Defendant Priscilla Rocha (Nevada LULAC State Director
and Member of the LULAC National Board of Directors) depositing the checks into a bank account
attributed to Olveritas Tradition Folklore, LLC, of which Defendant Priscilla Rocha (Nevada LULAC State
Director and Member of the LULAC National Board of Directors) is sole owner, thereby misrepresenting
the recipient of the money, and using said deposit for her own personal benet without authorization
from the Clark County School District. 33 SBIGI I'tll'tl JBGJI I I .DDCX IN Int rl Ft tI Il rI hI 14 IrOMIJI
43- LIJ

COUNT 41 - THEFT

knowingly, feloniously, and without lawll authority, obtain lawful money of the United States in the
amount of $3,500.00 or more, belonging to the CLARK COUNTY SCHOOL DISTRICT, by a material
directing and authorizing Clark County School District employee Renee Romero to create checks #1214,
1220, 1222, 1223, 1225, 1232, and 1235 from Bank of America account ending in #8801, made payable
to Olveritas Village, 648 N. Main St, Los Angeles, CA, totaling $27,707.00, and then Defendant Priscilla
Rocha (Nevada LULAC State Director and Member of the LULAC National Board of Directors) depositing
the checks into a bank account attributed to Olveritas Tradition Folklore, LLC, of which Defendant
Priscilla Rocha (Nevada LULAC State Director and Member of the LULAC National Board of Directors) is
sole owner, thereby misrepresenting I the recipient of the money, and using said deposit for her own
personal benet without authorization from the Clark County School District.


Directors) did on or between January 1, 2013 and December 31, 2013 then and there wilJlly,
knowingly, feloniously, and without lawJl authority being a pubic ofcer or other person who has in her
safekeeping or for transmission to any treasurer or other officer, or other person entitled to receive it,
1222, 1223, 1225, 1232, and 1235 from Bank of America account ending in #8801 which is funded with
Lab fees collected from the students of the AELAS program, made payable to Olverita's Village, 648 N.
Main St, Los Angeles, CA, totaling $27,707.00, and then Defendant Priscilla Rocha (Nevada LULAC State
Director and Member of the LULAC National Board of Directors) depositing the checks into a bank
account attributed-to 34 WlJB'tGIl'tl 31133611 .DGCX 1'J'l DJ Mili RD 09"4 Ch U1 C: Olveritas
Tradition 8r. Folklore, LLC, of which Defendant Priscilla Rocha (Nevada LULAC State Director and
Member of the LULAC National Board of Directors) is sole owner, thereby misrepresenting the recipient
of the money, and using said deposit for her own personal benet without authorization from the Clark
County School District.

COUNT 43 - THEFT

Directors) did on Or about February 27, 2013 then and there wilfully, knowingly, feloniously, and
without lawful authority, use the 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,
having a value of $65 0.00 or more, belonging to the Clark County School District, in the following
manner, towit: by using money from Bank of America account ending in #8801, which contained money
collected from students of the AELAS program paid in exchange for Lab fees, having Clark County
School District employee Renee Romero author check #1217 made payable to the League of United
Latin American Citizens (LULAC) for $3,011.80 not for ofcial or authorized uses, but for her own
personal gain or reasons.


Directors) did on or about February 27, 2013 then and there wilfully, knowingly, feloniously, and
without lawful authority being a pubic ofcer or other person who has in her possession, control, or
custody any public. money belonging to this state or any county, town, city, district, or municipal
transmission to any treasurer or other ofcer, 1 I or other person entitled to receive it, who uses any of
the public money for his or her own private purposes, or for any purpose other than one authorized by
law, the amount unlawfully used being $650.00 or more, in the following manner, to wit: in her position
of Director of the AELAS program for the Clark County School District by using money from Bank of
America account ending in #8801, which contained money collected from students of the AELAS
program paid in exchange for Lab fees, having Clark County School District employee Renee Romero
author check #1217 made payable to the League of United Latin American 35 3U JBGH .DOCX M-M It vI
DO ON 43-.UJ OD 0% U1 UJ C3 Citizens (LULAC) for $3,011.80 not for ofcial or authorized uses, but for
her own personal i gain or reasons.

COUNT 45 THEFT

without lawful authority, use the 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,
having a value of $650.00 or more, belonging to the Clark County School District, in the following
manner, towit: by using money 'om Bank of America account ending in #8801, which contained money
collected from students of the AELAS program paid in exchange for Lab fees, having Clark County
School District employee Renee Romero author check #1240 made payable to the League of United
Latin American Citizens (LULAC) for $708.00 not for official or authorized uses, but for her own personal
gain or reasons.


without lawful authority being a pubic ofcer or other person who has in her possession, control, or
custody any public money belonging to this state or any county, town, city, district, or municipal
transmission to any treasurer or other officer, or other person entitled to receive it, who uses any of the
public money for his or her own private purposes, or for any purpose other than one authorized by law,
the amount unlawilly used being $650.00 or more, in the following manner, to wit: in her position of
Director of the AELAS program for the Clark County School District by using money from Bank of
America account ending in #8801, which contained money collected from students of the AELAS
program paid in exchange for Lab fees, having Clark County School District employee Renee Romero
author check #1240 made payable to the League of United Latin American Citizens (LULAC) for $708.00
not for ofcial or authorized uses, but for her own personal gain or reasons.

COUNT 47 THEFT

Directors) did on or about May 30, 2013 then and there wilfully, knowingly, feloniously, and without
lawful authority, use the 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, having a value of
$3,500.00 or more, belonging to the Clark County School District, in the following manner, to-wit: by
using money from Wells Fargo Checking account number 6981, which contained money collected from
students of the AELAS program paid in exchange for ID Cards made by Clark County School District
Employees during working hours, having Renee Romero author check #1091 from this account for
$5000.00 to Alfonso Acosta, not for ofcial or authorized uses, but for the purchase of the Yamilex
Beauty Salon for Defendant Priscilla Rocha (Nevada LULAC State Director and Member of the LULAC
National Board of Directors) s own personal gain.


Directors) did on or about May 30, 2013 then and there wilfully, knowingly, feloniously, and without
lawful authority being a pubic officer or other person who basin her possession, control, or custody any
public money belonging to this state or any county, town, city, district, or municipal corporation within
this state, or to whom any such public money is entrusted for safekeeping or for transmission to any
treasurer or other officer, or other person entitled to receive it, who uses any of the public money for
his or her own private purposes, or for any purpose other than one authorized by law, the amount
unlawfully used being $650.00 or more, in the following manner, to wit: in her position of Director of the
AELAS program for the Clark County School District by using money from Wells Fargo Checking account
number 6981, which contained money collected from students of the AELAS program paid in exchange
for ID Cards made by Clark County School District Employees during working hours, having Renee
Romero author check #1091_ from this account to Alfonso Acosta, not for ofcial or authorized uses, but
.for the I purchase of the Yamilex Beauty Salon for Defendant Priscilla Rocha (Nevada LULAC State
Director and Member of the LULAC National Board of Directors) s own personal gain. - If 37 0O *4 Ch
U1 43 Ln) CHE-D 0 4 ON U1 LIJ

COUNT 49 - THEFT

Directors) did on or about July 8, 2013 then and there wilfully, knowingly, feloniously, and without
lawful authority, use the 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, having a value of
$650.00 or more, belonging to the Clark County School District, in the following manner, to-wit: by using
money from Wells 3 Fargo Checking account number 6981, which contained money collected from
students of the l AEEAS program paid in exchange for ID Cards made by Clark County School District.
Employees during working hours, having Renee Romero author check #1098 from this account for
$2,500.00 to Priscilla Rocha (Nevada LULAC State Director and Member of the LULAC National Board of
Directors) , not for ofcial or authorized uses, but for her own personal gain.


Directors) did on or about July 8, 2013 then and there wilfully, knowingly, feloniously, and without
lawful authority being a pubic ofcer or other person who has in her possession, control, or custody any
treasurer or other ofcer, or other person entitled to receive it, who uses any of the public money for his
or her own private purposes, or for any purpose other than one authorized by law, the amount
unlawfully used being $650.00 or more, in the following manner, to wit: in her position of Director of the
AELAS program for the Clark County School District by using money from Wells Fargo Checking account
number 6981, which contained money collected from students of the AELAS program paid in exchange
for ID Cards made by Clark County School District Employees during working hours, having Renee
Romero author check #1098 from this account for $2,500.00 to Priscilla Rocha (Nevada LULAC State
Director and Member of the LULAC National Board of Directors) , not for ofcial or authorized uses, but
for her own personal gain. 38 WHO 133161111311 33511 .DOCX

COUNT 51 - THEFT

Directors) did on or between June 18, 2013 and June 20, 2013 then and there wilfully, knowingly,
feloniously, and without lawful authority, use the 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, having a value of $650.00 or more, belonging to the Clark County School District, in the following
manner, to-wit: by using money from Wells Fargo Checking account number 6981, which contained
money collected from students of the AELAS program paid in exchange for ID Cards made by Clark
County School District Employees during working hours, having Renee Romero author check #1093 for
$964 made payable to Lois Toney for Shirts, check #1096 for $960.00 made payable to Priscilla Rocha
(Nevada LULAC State Director and Member of the LULAC National Board of Directors) for Lulac
Delegates and check #1095 for $1,140.00 made payable to Lulac for presentations, totaling $3,064.00
not for ofcial or authorized uses, but for her own personal gain or reasons.


Directors) did on or about June 20, 2013 then and there wilfully, knowingly, feloniously, and without
lWJl authority being a pubic ofcer or other person who has in her possession, control, or custody any
treasurer or other ofcer, or other person entitled to receive it, who uses any of the public money for his
or her own private purposes, or for any purpose other than one authorized by law, the amount
unlawfully 4 used being $650.00 or more, in the following manner, to wit: in her position of Director of
the - AELAS program for the Clark County School District: by using money from Wells Fargo Checking
account number 6981, which contained money collected from students of the AELAS program-paid in
exchange for ID Cards made by Clark County School District Employees during working hours, having
Renee Romero author check #1093 for $964 made payable to Lois Toney for Shirts, check #1096 for
$960.00 made payable to Priscilla Rocha (Nevada LULAC State Director and Member of the LULAC
National Board of Directors) for Lulac Delegates and check #1095 for $1,140.00 made payable to Lulac
39 {0er b tI rt GO d-_Ch for presentations, totaling $3,064.00 not for ofcial or authorized uses, but
for her own personal gain or reasons.

DATED this i day ofJuly, 2014.

ENDORSEMENT: A True Bill STEVEN B. WOLFSON Clark County District Attorney Nevada Bar #00156 BY
JAY P. RAMAN Chief De uty District Attorney Nevada ar #10193 Foretyn, glark County Grand Jury 40 '51
Ch L11 '45 LIJ C3

Names of witnesses testifying before the Grand Jury:

DIAZ, CESAR, UNKNOWN ADDRESS
ESPITIA, JAIME, UNKNOWN ADDRESS
FAILEY, NICK, UNKNOWN ADDRESS
HAYNES, COLIN; LIZOTTE, DENNIS, UNKNOWN ADDRESS
ALICH, TAMMY, UNKNOWN ADDRESS
MENDOZA, ANDRES, UNKNOWN ADDRESS
RAMIREZ, MANUEL, UNKNOWN ADDRESS
REYNOLDS, ROSA, UNKNOWN ADDRESS
RIVERA, MARIA, UNKNOWN ADDRESS
ROMERO, RENEE, UNKNOWN ADDRESS
SCHOEN, WILLIAM, SOTO, ANNA, UNKNOWN ADDRESS
VERLANDA, ALBUQUERQUE POLICE DEPT.
VARGAS, ESTHER, UNKNOWN ADDRESS
WHITELEY, ROBERT, ZAPATA, CLAUDIA
UNKNOWN ADDRESS
Additional witnesses known to the District Attorney at time of ling the Indictment: 13BGJI (TK) 41

Counts in The Indictment of Priscilla Rocha

Transféré par

Informations du document

Titre original

Copyright

Formats disponibles

Partager ce document

Partager ou intégrer le document

Options de partage

Avez-vous trouvé ce document utile ?

Ce contenu est-il inapproprié ?

Droits d'auteur :

Formats disponibles

Counts in The Indictment of Priscilla Rocha

Transféré par

Droits d'auteur :

Formats disponibles

Electronically Filed 07/18/201412217212 PM

CLERK OF THE COURT IND STEVEN B. WOLFSON

Vous aimerez peut-être aussi