KAMAIA D. HARRIS Attorney General of California ROBERT MORGESTER Senior Assistant Attorney General RANDY MAILMAN Deputy Attorney General MAGGY KRELL Supervising Deputy Attorney General State Bar No. 226675 . 13001 Street, Suite 125 By FRANCE PD. Box 944255 Sacramento, CA 94244?2550 Telephone: (916) 327-1995 Fax: (916) 322-2368 Attorneys for the People of the State of California an?. 23 201:5 SUPERIOR COURT OF THE STATE OFCALIFORNLA IN AND FOR THE COUNTY OF SACRAMENTO PEOPLE OF THE STATE OF Case No. /5 @5194? 3 CALIFORNIA, Plaintiff, 1. CARL FERRER FELONY CRIMINAL COMPLAINT (1303:?) (Xref Date: January 11, 2017 (nos: em; (Xref am Depanmem, 3. JANIES LARKIN (DOB: w) (Xref Defendants. 1, the undersigned, say on information and belief, that in the County of Sacramento, State of California: If CRIMINAL COMPLAINT I-J gt?ig?b?m?i?tgmmummemmi?n: COUNT ONE (Penal Code sections 182f136.10, MONEY LAUNDERING CONSPIRACY) On or between January 1, 2013 and September 1, 2016, in the County of Sacramento and throughout the State of California, DEFENDANTS FERRER, LACEY, and LARKIN did unlawfully commit the crime of CONSPIRACY in violation of section 182(a)(1) of the Penal Code in that said Defendants did unlawfully conspire together with each other and with others whose identities are known and unknown, to commit the crime of money laundering, in violation of section 186.10 of the Penal Code, a felony; and that pursuant to and for the purposes of carrying out the objectives of the aforesaid conspiracy, the. said Defendants committed the following overt acts, throughout the alleged time period: Hf Overt Act 1 Defendants owned and operated multiple websites, including Backpage.com. Overt Act 2 On August 27, 2013, Defendant Ferrer noti?ed Backpage personnel that customers? payment attempts were being denied and credit processors were refusing to process Backpage transactions because of overtly sexual content and questionable practices. Overt Act 3 Defendants created the company, Classified Solutions, LTD. Overt Act 4 Defendants created the company, Website Technologies, LLC. Overt Act 5 Defendants created the company Postfaster LLC and made Nathan Kopecky, Backpage?s Chief Financial Officer, the President. Overt Act 6 Defendants applied for merchant accounts for said companies. Overt Act 7 Defendants created multiple classified sites including Ymas, Postfastr, and Truckrjohs. CRIMINAL COMPLAINT Overt Act 8 Defendant Ferrer applied for a merchant account with the payment processor Stripe for the classified site Postfastr.com. He omitted any reference to but planned to use the accent to process Backpage. transactions. Overt Act 9 After Stripe notified Defendant Ferrer that it was closing the account, Defendant Ferrer directed Kopecky to tell Stripe that Postfaster LLC had no connection to Backpage and was a site that hosted ads for truck drivers and other jobs. Overt Act 10 In early 2015, Defendant Fer-rer received notice from American Express that the company would not process Backpage transactions after May 1, 2015. Defendant Ferrer directed Backpage personnel to ?bury? a message notifying users that American Express would not be accepted, but to process any Ammican Express payments that Backpage users attempted. Overt Act 11 Defendant Ferrer also directed Backpage personnel to contact American Express users and guide them through a process to use American Express to purchase ?credits? on Postfastr.com which could then be used on Backpagecom. Overt Act 12 In May of 2015, Defendants conducted $48,288.85 in American Express transactions from Backpage?s female Escort section throughout California, including Sacramento County. Overt Act 13 In May of 2015, Defendants conducted $7,904.00 in credits purchased via American Express on Postfastr.com. Overt Act 14 In June of 2015, Defendants conducted $31,786.25 in American Express transactions from Backpage?s female Escort section throughout California, including Sacramento County. CRIMINAL COMPLAINT Overt Act 15 In June of 2015, Defendants conducted $16,152.32 in credits purchased via American Express on Postfastr.co'm. Overt Act 16 In July of 2015, defendants conducted $11,105.78 in American Express transactions from Backpage?s female Escort section users throughout California, including Sacramento enunty. Overt Act 17 From July 1 through 7, 2015, Defend-ants cenducted $8,771.90 in credits purchased via American Express on Postfastr.con1. Overt Act 13 Defendant Ferret directed Backpage personnel to alter billing descriptors on Backpage.com transactions to eliminate references to Backpage. Overt Act 19 Between August 1, 2013 and October 31, 2016, Defendants received approximately $45,202,288.49 from transactions initially purchased through Backpagecom?s Escort categories throughout California, including Sacramento County. COUNT TWO (Penal Code section MONEY LAUNDERING) On or about and between July 1, 2014 and July 31, 2014, throughout California, including Sacramento County, the crime of MONEY LAUNDERING, in violation of Penal Code section a felony, was committed by Defendants, who did willfully and unlawfully conduct transactions involving monetary instruments of a total value exceeding $25,000, to wit: $1,082,934.67; knowing that Such monetary instrument or instruments represent the proceeds of, or is derived directly or indirectly from the proceeds of criminal activity. 1? CRIMINAL COMPLAINT COUNT THREE (Penal Code seetion MONEY LAUNDERING) On or about and between August 1, 2014 and August 31, 2014, throughout California, including Sacramento County, the crime of MONEY LAUNDERING, in violati0n of Penal Code section a felony, was committed by Defendants, who did willfully and unlawfully conduct transactions involving monetary instruments of a total value exceeding $25,000, to wit: $2,063,128.70; knowing that such monetary instrument or instruments represent the proceeds of, or is derived directly or indirectly from the proceeds of criminal activity. COUNT FOUR (Penal Code section MONEY IAUNDERING) On or about and between September 1, 2014 and September 30, 2014, throughout California, including Sacramento County, the crime of MONEY LAUNDERING, in violation of Penal Code section a felony, was committed by Defendants, who did willfully and unlawfully conduct transactions involving monetary instruments of a total value exceeding $25,000, to wit: $2,036,152.04; knowing that such monetary instrument or instruments represent the proceeds of, or is derived directly or indirectly from the proceeds of criminal activity. COUNT FIVE- {Peual Code section MONEY LAUNDERING) On or about and between October 1, 2014 and October 31, 2014, throughout California, including Sacramento County, the crime of MONEY LAUNDERING, in violation of Penal Code section a felony, was committed by Defendants, who did willfully and unlawfully conduct transactions involving monetary instruments of a total value exceeding $25,000, to wit: $2,212,972,21; knowing that such monetary instrument or instruments represent the proceeds of, or is derived directly or indirectly from the-proceeds of criminal activity. COUNT 81X (I?enal Code section MONEY LAUNDERING) On or about and betnreen November 1, 2014 and November 30, 2014, throughout California, including Sacramento County, the Crime of money MONEY LAUNDERING, in I 5 CRIMINAL COMPLAINT violation of Penal Code section a felony, was committed by Defendants, who did willfully and unlawfully conduct transactions involving monetary instruments of a total value exceeding $25,000, to wit: $2,1 48,3915 2; knowing that such monetary instrument or instruments represent the proceeds of, or is derived directly or indirectly from the proceeds of criminal activity. COUNT SEVEN (Penal Code section MONEY On or about and between December 1, 2014 and December 31, 2014, throughout California, including Sacramento County, the crime of MONEY LAUNDERLNG, in violation of Penal Code section a felony, was committed by Defendants, who did willfully and unlawfully conduct transactions involving monetary instruments of a total value exceeding $25,000, to wit: $2,252,053.16; knowing that such monetary instrument or instruments represent the proceeds of, or is derived directly or indirectly from the proceeds of criminal activity. COUNT EIGHT {Penal Code section MONEY LAUNDERING) On or about and between January 1, 2015 and January 31, 2015, throughout California, including Sacramento County, the crime of MONEY LAUNDERING, in violation of Penal Code section a felony, was committed by Defendants, who did willfully and unlawfully conduct transactions. involving monetary instruments of a total value exceeding $25,000, to wit: $2,338,789.97; knowing that such monetary instrument or instruments represent the proceeds of, Dr is derived directly or indirectly from the proceeds of criminal activity. COUNT NINE (Penal Code section MONEY LAUNDERIN G) On or about and between February 1, 2015 and February 28, 2015, throughout California, including Sacramento County, the crime of MONEY LAUNDERING, in violation of Penal Code section a felony, was committed by Defendants, who did willfully and unlawfully conduct transactions involving monetary instruments of a total value exceeding $25,000, to wit: CRIMINAL COMPLAINF 25 26 27 28 $2,185,513.27; knowing that such monetary instrument or instruments represent the proceeds of, or is derived directly or indirectly from the proceeds of criminal activity. COUNT TEN (Penal Code section MONEY LAUNDERING) On or about and between March 1, 2015 and March 31, 2015, throughout California, including SaCramento County, the crime of MONEY LAUNDERING, in violation of Penal Code section a felony, was committed by Defendants, who did willfully and unlawfully conduct transactioos involving monetary instruments of a total value exceeding $25,000, to'wit: $2,556,274.11; knowing that such monetary instrument. or instruments represent the proceeds of, or is derived directly or indirectly from the proceeds of criminal activity. COUNT ELEVEN (Penal Code section MONEY LAUNDERING) On or about and between April 1, 2015 and April 30, 2015, throughout California, including Sacramento County, the crime of MONEY LAUNDERING, in violation of ?Penal Code section a felony, was committed by Defendants, who did willfully and unlawfully conduct transactions involving monetary instruments of a total value exceeding $25,000, to wit: $2,620,805 .68; knowing that such monetary instrument or instruments represent the proceeds of, or is derived directly or indirectly from the proceeds of criminal activity. COUNT TWELVE {Penal Code section MONEY On or about and between May 1, 2015 and May 31, 2015, throughout California, including Sacramento County, the crime of MONEY LAUNDERING, in violation of Penal Code section a felony, was committed by Defendants LARKIN AND FERRER, who did willfully and unlawfully conduct transactions involving monetary instruments of a total value exceeding $25,000, to wit: $48,288.85; knowing that such monetary instrument or instruments represent the proceeds of, or is derived directly or indirectly from the proceeds of criminal activity. Hf CRIMINAL COMPLAINT KG 00' ON U?t L13 to 5-4 but 1?1 1?1 l?ui r?r COUNT THIRTEEN (Penal Code Section MONEY LAUNDERING) On 0r about and between June 1, 2015 and June 30, 2015., throughout California, including Sacramento County, the crime of MONEY LAUNDERING, in violation of Penal Code section a felony, was committed by Defendants LARKIN AN FERRER, who did willfully and unlawfully conduct transactions involving monetary instruments of a total value exceeding $25,000, to wit: $31,786.25; knowing that such monetary instrument or instruments represent the proceeds of, or is derived directly or indirectly from the proceeds of criminal activity. COUNT FOURTEEN (Penal Code section MONEY LAUNDERIN G) On or about and between July 1, 2015 and July 30, 2015, throughout California, including Sacramento County, the crime of MONEY LAUNDERING, in violation of Penal Code section a felony, was committed by Defendants, who did willfully and unlawfully conduct transactions involving monetary instruments of a total value exceeding $25,000, to wit: $598,695.98; knowing that such monetary instrument or instruments represent the proceeds of, or is derived directly or indirectly from the proceeds of criminal activity. COUNT (Penal Code section MONEY LAUNDERING) On or about and between August 1, 2015 and August 31, 2015, throughout California, including Sacramento County, the crime-of. MONEY IAUNDERING, in violation of Penal Code section a felony, was committed by Defendants, who did willfully and unlawfully conduct transactions involving monetary instruments of a total value exceeding $25,000, to wit: $383,801.33; knowing that such monetary instrument or instruments. represent the proceeds of, or is derived directly or indirectly from the proceeds of criminal activity. a? CRIMINAL COMPLAINT COUNT SIXTEEN (Penal Code section MONEY IAUNDERING) On or about and between September 1,2015 and September 30 2015, throughout California, including Sacramento County, the crime of MONEY LAUNDERING, in violation of Penal Code section a felony, was committed by Defendants, who did willfully and unlawfully conduct transactions involving monetary instruments of a total value exceeding $25,000, to wit: $347,802.26; knowing that such monetary instrument or instruments represent the proceeds of, or is derived directly or indirectly from the proceeds of criminal activity. COUNT SEVENTEEN (Penal Code section MONEY On or about and between October 1, 2015 and October 31, 2015, throughout CalifOrnia, including Sacramento County, the crime of MONEY LAUNDERING, in violation of Penal Code section a felony, was committed by Defendants, who did willfully and unlawfully conduct transactions involving monetary instruments of a total value exceeding $25,000, to wit: $211,060.93; knowing that such monetary instrument or instruments represent the proceeds of, or is derived directly or indirectly from the proceeds of criminal activity. COUNT EIGHTEEN (Penal Code section MONEY LAUNDERING) On or about and between November 1, 2015 and November 30, 2015, throughout California, including Sacramento County, the crime of MONEY LAUNDERING, in violation of Penal Code section a felony, was committed by Defendants, who did willfully and unlawfully conduct transactions involving monetary instruments of a total value exceeding $25,000, to wit: $290,762.69; knowing that such monetary instrument or instruments represent the proceeds of, or is derived directly or indirectly from the proceeds of criminal activity. COUNT NINETEEN (Penal Code section MONEY LAUNDERING) On or about and between December 1, 2015 and December 31, 2015, throughout California, including Sacramento County, the crime of MONEY LAUNDERING, in violation of 9 CRIMINAL COMPLAINT l?l- I?Ll-Ji??l?ll?h-?Hl?ll?Ih?ll?l E?gi??l?o?mgemommemmue Penal Code section a felony, was committed by Defendants, who did willfully and unlawfully conduct transactions involving monetary instruments of a total value exceeding $25,000, to wit: $1,169,547.13; knowing that such monetary instrument or instruments represent the proceeds of, or is derived directly or indirectly from the proceeds of criminal activity. COUNT TWENTY (Penal Code section MONEY LAUNDERING) On or about and between January 1, 2016 and January 31, 2016, throughout California, including Sacramento County, the crime of MONEY LAUNDERING, in violation of Penal Code section a felony, was committed by Defendants, who did willfully and unlawfully conduct transactions involving monetary instruments of a total value exceeding $25,000, to wit: $1,273,683.55; knowing that such monetary instrument or instruments represent the proceeds of, or is derived directly or indirectly from the proceeds of criminal activity. COUNT TWENTY ONE (Penal Code section MONEY LAUNDERIN G) On or about and between February 1, 2016 and February 28, 2016, throughout California, including Sacramento County, the crime of MONEY LAUNDERING, in violation of Penal Code section a felony, was committed by Defendants, who did willfully and unlawfully conduct transactions involving monetary instruments of a total value exceeding $25,000, to wit: knowing that such monetary instrument or instruments represent the proceeds of, or is derived directly or indirectly from the proceeds of criminal activity. COUNT TWENTY TWO (Penal Code section MONEY LAUNDERING) On or about and between March 1, 2016 and March 31, 2016, throughout California, including Sacramento County, the crime of MONEY LAUNDERING, in violation of Penal Code section a felony, was committed by Defendants, who did willfully and unlawfully conduct transactions involving monetary instruments of a total value exceeding $25,000, to wit: $1,283,050.72; knowing that such monetary instrument or instruments represent the proceeds of, or is derived directly or indirectly from the proceeds of criminal activity. '10 CRIMINAL COMPLAINT crime-tutu ROUGECOUNT TWENTY THREE (Penal Code section MONEY On or about and between April 1, 2016 and April 30, 2016, throughout California, including Sacramento County, the crime of MONEY LAUNDERING, in violation of Penal Code section a felony, was committed by Defendants, who did willfully and unlawfully conduct transactions involving monetary instruments of a total value exceeding $25,000, to wit: $1,387,266.85; knowing that such monetary instrument or instruments represent the proceeds of, or is derived directly or indirectly from the proceeds of criminal activity. COUNT TWENTY FOUR (Penal Code section MONEY LAUNDERING) On or about and between May 1, 2016 and May 31, 2016, throughout California, including Sacramento County, the crime of MONEY LAUNDERJNG, in violation of Penal Code section a felony, was committed by Defendants, who did willfully and unlawfully conduct transactions involving monetary instruments of a total value exceeding $25,000, to wit: $1,477,020.43; knowing that such monetary instrument or instruments represent the proceeds of, or is derived directly or. indirectly from the proceeds of criminal activity. COUNT TWENTY FIVE (Penal Code section Isolation), MONEY On or about and between June 1, 2016 and June 30, 2016, throughout California, including Sacramento County, the crime of LAUNDERING, in violation of Penal Code section a felony, was committed by Defendants, who did willfully and unlawfully conduct transactions involving monetary instruments of a total value exceeding $25,000, to wit: $l,e69,458.14; knowing that such monetary instrument or instruments represent the proceeds of, or is derived directly or indirectly from the proceeds of criminal activity. COUNT TWENTY SIX (Penal Code section MONEY LAUNDERING) On or about and between July 1, 2016 and July 31, 2016, throughout California, including Sacramento County, the crime of MONEY LAUNDERING, in violation of Penal Code section 11. CRIMINAL COMPLAINT felony, was committed by Defendants, who did willfully and unlawfully conduct transactions involving monetary instruments of a total value exceeding $25,000, to wit: $1,534,210.45; knowing that Such monetary instrument or instruments represent the proceeds of, or is derived directly or indirectly from the proceeds of criminal activity. COUNT TWENTY SEVEN (Penal Code section MONEY LAUNDERING) On or about and between August 1, 2016 and August 31, 2016, throughout California, including Sacramento County, the crime of MONEY LAUNDERING, in violation of Penal Code . section a felony, was committed by Defendants, who did willfully and unlawfully conduct transactions involving monetary instruments of a total value exceeding $25,000, to wit: $1,5 64,182.72; knowing that such monetary instrument or instruments represent the proceeds of, or is derived directly or indirectly from the proceeds of criminal activity. COUNT TWENTY EIGHT (Penal Code sections 182i266h, PIMPING On Dr between January 1, 2010 and September 28, 2016, in the County of Sacramento and throughout the State of California, Defendants did unlawfully commit the crime of CONSPIRACY in violation of section 182(a)(1) of the Penal Code in that said Defendants did unlawfully cunspire together with each other and with others 'whose identities are known and unknown, to commit the crime of pimping, in violation of section 26611 of the Penal Code, a felony; and that pursuant to and for the purposes of carrying out the objectives of the aforesaid conspiracy, the said Defendants committed the following overt acts, throughout the alleged time period: Overt Act 1 On or about September 10, 2014, Defendants received prostitution earnings from A.C., a minor, in Sacramento County. Overt Act 2 On or about August 19, 2014, Defendants received prostitution earnings from E.V., a minor, in Los Angeles County. 12 CRIMINAL COMPLAINT Overt Act 3 On or about February 8, 2015, Defendants received prostitution earnings from a minor, in Santa Clara County. Overt Act 4 On or about February 1, 2015, Defendants received prostitution earnings from 213., a minor, in Los Angeles Cunnty. Overt Act 5 On or about October 7, 2012, Defendants received prostitution earnings from A.H. in Sacramento County. Overt Act 6 On er about July 30, 2014, Defendants received prostitution earnings from SC. in Sacramento County. Overt Act 7 On or about August 19, 2014, Defendants received prostitution earnings from LB. in Los Angeles County. Overt Act 8 On or about April 4, 2015, Defendants received prostitution earnings from K.A. in Sacramento County. Overt Act 9 On or about November 6, 2015, Defendants received prostitution earnings from C.U., a minor, in Sacramento County. Overt Act 10 On or about August 12, 2016, Defendants received prostitution earnings from A.B., a minor, in Fresno County. Overt Act 11 On or about November 22, 2015, Defendants received prostitution earnings from A.F. in Sacramento County. 13. CRIMINAL COMPLAINT Overt Act 12 Between December 6, 2015 to December 28, 2015, Defendants received prostitution earnings from a minor, in Santa Clara County. Overt Act 13 Defendants owned and operated multiple websites, including Backpagecom. Overt Act 14 Defendants used Backpagecom to collect the earnings of prostitutes and their pimps. Overt Act 15 Defendants designed and used other websites to increase web traffic to Backpagecorn and thereby increase its own revenue from the illegal sex trade. Overt Act 16 Defendants designed two of their websites, BigCity and EvilErnpire, using content developed by Defendants and their employees with the purpose of promoting Backpage?s prostitution business and monopolizing the market. Overt Act Defendants created pro?les for thousands of victims, including minors, on BigCity and EvilEmpire. Overt Act 18 Defendants created profiles for the victims named in counts 29, 3t}, 31, 32, 35, 36, 37?40 without their knowledge. Overt Act 19 Victims could not remove or edit the pictures or information the defendant?s placed on EvilEmpire and when one victim contacted Backpage, staff replied that Backpage was not affiliated with EvilEmpi're and could not remove her picture. Overt Act 20 Defendants created other websites that were unrelated to prostitution. Defendants used these websites to process prostitution?related transactions when financial institutions were unwilling to conduct business with Defendants. I 14 CRIMINAL COMPLAINT 051.!!COUNT TWENTY NINE (Penal Code section PIMPING A MINOR UNDER 16 YEARS OF AGE) For a further and separate cause of action, being a different offense from, but connected in its commission with, the charge set forth above, on or about and between September 1, 2014 through December 31, 2014, in the County of Sacramento, Defendant FERRER did unlawfully commit the crime of PIMPING OF A MINOR, in violation of Penal Code section 266h(b)(2), in that said Defendant, knowing a minor under 16 years of age, to engage in prostitution, did live and derive support and maintenance in whole or in part from the earnings and proceeds of said prostitution. COUNT THIRTY (Penal Code section 266h(b)(2), PIMPING A MINOR UNDER 16 YEARS OF AGE) For a further and separate cause of action, being a different offense from, but connected in its commission with, the charge set forth above, on or about and between August 1, 2014 through January 1, 2015, in the County of Los Angeles, Defendant FERRER did unlawfully commit the crime of PIMPINO OF A MINOR in violation of Penal Code section 266h(b)(2), in that said Defendant, knowing E.V., a minor under 16, to be a prostitute, did live and derive support and maintenance in whole or in part from the earnings and proceeds of said prostitution. COUNT THIRTY ONE {Penal Code section 266h(b)(2), PIMPING A MINOR UNDER 16 YEARS OF AGE) For a further and separate cause of action, being a different offense from, but connected in its commission with, the charge set forth above, on or about and between January 1, 2015 through February 28, 2015, in the County of Santa Clara, Defendant FERRER did unlawfully commit the crime of PIMPING OF A MINOR in violation of Penal Code section 266h(b)(2), in that said Defendant, knowing L.F., a minor under 16 years, to engage in prostitution, did live and derive support and maintenance in whole or in part from the earnings and proceeds of said prostitution. I r' I Hi 15 CRIMINAL COMPLAINT 24 26 27 28 COUNT THIRTY TWO (Penal Code section 266h PIMPING A MINOR) For a further and separate cause of action, being a different offense from, but connected in its commission with, the. charge set forth above, on or about and between one 1, 2015 through September 30, 2015, in the County of Los Angeles, Defendant FERRER did unlawfully commit - the crime of PIMPING OF A MINOR in violation of Penal Code section 266h(b)(1), in that said Defendant, knowing 2.6., a minor, to engage in prostitution, did live and derive support and maintenance in whole or in part from the earnings and proceeds of said prostitution. COUNT THIRTY THREE (Penal Code section 266h(a), PIMPING) For a further and separate cause of action, being a different offense from, but connected in its commission with, the charge set forth above, on or about and between April 28, 2014 through March 6, 2,015, in the County of Sacramento, Defendant FERRER did unlawfully commit the crime of PIMPING in violation of PenalCode section 266h(a), in that said Defendant, knowing All. to be a prostitute, did live and derive Support and maintenance in whole or in part from the earnings and proceeds of said prostitution. COUNT THIRTY FOUR (Penal Code section 266h(a), PIMPING) For a further and separate cause of action, being a different offense from, but connected in its commission with, the charge set forth above, on or about and between July 1, 2014 through August 31, 2015, in the County of Sacramento, Defendant FERRER did unlawfully commit the crime of PIMPING in violation of Penal Code section 266h(a), in that said Defendant, knowing S.C. to be a prostitute, did live and derive support and maintenance in whole or in part from the earnings and proceeds of said prestitution. COUNT THIRTY FIVE (Penal Code section 2661101), PIMPING) For a further and separate cause of action, being a different offense from, but connected in its conunissioa with, the charge set forth above, on or about and between August 1, 2014 and 16 CRIMINAL COMPLAINT Hi?LHi?ti?ts?ir?at?tI?La?I 24 26- 27 2.8 August 31, 2014, in the County of Los Angeles, Defendant FERRER did unlawfully commit the crime of PIMPING in violation of Penal Code section 266h(a), in that said Defendant, knowing LE. to be a prostitute, 'did live and derive support and maintenance in whole or in part from the. earnings and proceeds of said prostitution. COUNT THIRTY SIX (Penal Code section 266hfa), PIMPIN G) For a further and separate cause of action, being a different offense from, but connected in its commission with, the charge set forth above, on or about and between January 1, 2016 to June 1, 2016 in the County of Sacramento, Defendant FERRER did unlawfully commit the crime of PIMPING in violation of Penal Code section 266h(a), in that said Defendant, knowing K.A. to be a prostitute, did live and derive support and maintenance in whole or in part from the earnings and proceeds of said prostitution. COUNT THIRTY SEVEN (Penal Code section 266h(b)(1), PIMPING A MINOR 16 YEARS OF AGE) For a further and separate cause of action, being a different offense from, but connected in its commission with, the charge set forth above, on or about and between November 1, 2014 through November 6, 3015, in the County of Sacramento, Defendant FERRER did unlawfully commit the crime of PIMPING OF A MINOR in violation of Penal Code section 266h(b)(1), in that said Defendant, knowing C.U., a minor over 16 years, to engage in prostitution, did live and derive support and maintenance in whole or in part from the earnings and proceeds of said prostitution. COUNT THIRTY EIGHT (Penal Code section PIMPING A MINOR 16 YEARS OF AGE) For a further and separate cause of action,- being a different offense from, but connected in its commission with, the charge set forth above, on or about August 12, 2016 in the County of Fresno, Defendant FERRER did unlawfully commit the crime. of PIMPING OF A MINOR in violation of Penal Code section 266h(b)(1), in that said Defendant, knowing A.B., a minor over 1? CRIMINAL COMPIAINT 16 years, 'to engage in prostitution, did live and derive Support and maintenance in whole or in part from the earnings and proceeds of said prostitution. COUNT THIRTY NINE (Penal Code section 2615b PIMPIN G) For a further and separate cause of action, being a different offense from, but connected in its commission with, the charge set forth above, on or about and between November 22, 2015 and December 5, 2015, in the County of Sacramento, Defendant FERRER did unlawfully commit the crime of PIMPING in violation of Penal Code section 266h(a), in that said Defendant, knowing A.F. to he a prostitute, did live and derive support and maintenance in-whoie or in part from the earnings and proceeds of said prostitution. COUNT FORTY (Penal Code section 266h(b)(2), PIMPING A MINOR UNDER 16 YEARS OF AGE) For a further and separate cause of action,.being a different offense from, but connected in its'commission with, the charge set forth above, on or about and between December 6, 2015 to December 28, 2015 in the County of Santa Clara, Defendant FERRER did unlawfully commit the crime of PIMPING OF A MINOR in violation of Penal Code section 266h(b)(2), in that said Defendant, knowing S.D., a minor under 16 years, to engage in prostitution, did live and derive support and maintenance in whole or in part from the earnings and proceeds of said prostitution. PENAL CODE SECTION 136.10 ENHANCEMENT ALLEGATION Pursuant to Penal Code section it is further alleged as to counts 14-18 that the value of the individually alleged transactions exceeds one hundred ?fty thousand dollars ($150,000) but is less than one million dollars so that the court, in addition to and consecutive to the felony punishment otherwise imposed pursuant to this section, shall impose an additional term of imprisonment of two years. PENAL CODE SECTION 186.10 ENHANCEMENT ALLEGATION Pursuant to Penal Code section it is further alleged as to counts 2-9, 19-26, that the value of the individually alleged transactions exceeds one million dollars but is less than two million five hundred thousand dollars so that the court, in 18 CRIMINAL COMPLAINT Ch U1 411 U) ?43 addition to and consecutive to the feiony punishment otherwise imposed pursuant to this section, shall impose an additional term of imprisonment of three years. PENAL CODE SECTION 186.10 ENHANCEMENT ALLEGATION Pursuant to Penal Code section it is further alleged as to counts 10-11, that the value of the individually alleged transactions exceeds two million five hundred thousand dollars so that the court, in addition to and consecutive to the felony punishment otherwise prescribed by this section, shall impose an additional term of imprisonment of four years. NOTICE: Conviction of the offenses charged in counts 28-32, 37-38, 40 will require yen to register pursuant to Penal Code section 290. Willfui failure to register is a crime. NOTICE: Per Penal Code sections 11166 and 11168, a Su5pected Child Abuse Report (SCAR) may have been generated in counts. 28-32, 37-38, 40. Penal Code sections 1116? and 11167-5 limit access to a SCAR. A court?issued protective order is needed to obtain a copy of the report. NOTICE: Penal Code section 1203.065(a) prohibits a grant of probation for the offenses charged in counts. 28-40. NOTICE: Per Penal Code section the People hereby informally request that defense counsel provide the People with discovery as required by Penal Code section 1054.3. DECLARATION I declare under penalty of perjury, under Penal Code section 806, that the foregoing is true and correct. Dated: December 23, 2016 Respectfully Submitted, KAMALA D. HARRIS Attorney General of California Manor KRELL Supervising Deputy Attorney General Attorneys for the People 5:51.20133115 83 32562043 19 CRIMINAL COMPLAINT