DEAN D. FLIPPO District Attorney MONTEREY COUNTY By: Carol Reed #201450 I Deputy District Attorney 230 Church Street Salinas, CA 93901 APR .1 4 2017 Telephone: (331) 755-5070 CLERK OF THE SUPERIOR COURT Attorneys for Plaintiff SUPERIOR COURT OF CALIFORNIA, COUNTY OF MONTEREY SALINAS DIVISION The People of the State of California No.33 iq' U?q [Or Plaintiff? WCF17-0025 vs. i A I I IANN THAN ELCZ RBAIN DACase: 839288 COMPLAINT PM Defendant. The District Attorney of Monterey County, California hereby accuses the above named defendant of the following criminal offenses occurring in the County of Monterey, State of California. Count 1 Insurance Fraud - FELONY as to Ian Nathaniel Czirban On or about November 24, 2014 - February 14, 2014, in the County of Monterey, the crime of INSURANCE FRAUD in violation of a FELONY, was committed by IAN NATHANIEL CZIRBAN, in that assisted, conspired with another to and did conceal and knowingly fail to disclose the occurrence of an event that affected a person's initial and continued Criminal Complaint DA File No.: 839288 District Attorney, County of Monterey Page 1 of 4 right and entitlement to an insurance bene?t and payment, and the amount of any bene?t and payment to which the person was entitled. Count 2 Insurance Fraud - FELONY as to Ian Nathaniel Czirban On or about January 28, 2013 - September 3, 2013, in the County of Monterey, the crime of INSURANCE FRAUD in violation of a FELONY, was committed by IAN NATHANIEL CZIRBAN, in that assisted, conspired with another to and did conceal and knowingly fail to disclose the occurrence of an event that affected a person's initial and continued right and entitlement to an insurance bene?t and payment, and the amount of any bene?t and payment to which the person was entitled. Count 3 Procuring And Offering False Or Forged Instrument - FELONY as to Ian Nathaniel Czirban On or about March 15, 2016, in the County of Monterey, the crime of PROCURING AND OFFERING FALSE 0R FORGED INSTRUMENT in violation of 15(a), a FELONY, was committed by IAN NATHANIEL CZIRBAN, in that IAN NATHANIEL CZIRBAN did unlawfully and knowingly procure and offer a false and forged instrument to be ?led, registered, and recorded in a public of?ce within this state, which instrument, if genuine, might be ?led, registered, and recorded under a law of this state or the United States. Count 4 Procuring And Offering False Or Forged Instrument - FELONY as to Ian Nathaniel Czirban On or about May 2, 2014, in the County of Monterey, the crime of PROCURING AND OFFERING FALSE OR FORGED INSTRUMENT in violation of 15(a), a FELONY, was committed by IAN NATHANIEL CZIRBAN, in that IAN NATHANIEL CZIRBAN did unlawfully and knowingly procure and offer a false and forged instrument to be ?led, registered, and recorded in a public of?ce within this state, which instrument, if genuine, might be ?led, registered, and recorded under a law of this state or the United States. Criminal Complaint DA File No.: 839288 District Attorney, County of Monterey Page 2 of 4 JimlCount 5 U12117.5: Acting with Intent to Evade Tax - FELONY as to Ian Nathaniel Czirban On or about June 20, 2015 - July 26, 2016, in the County of Monterey, the crime of ACTING WITH INTENT TO EVADE TAX in violation of UI21 17.5, a FELONY, was committed by IAN NATHANIEL CZIRBAN, in that IAN NATHANIEL CZIRBAN, who willfully fails to ?le any return or report, or to supply any information with intent to evade any tax imposed by this code, or who, and with like intent, makes, renders, signs, or veri?es any false or fraudulent return, report, or statement or supplies any false or ?audulent information to wit: Employment Development Department Payroll Tax Reports. Count 6 U12118.5: Failure to Collect, Account For, or Pay Over Taxes - FELONY as to Ian Nathaniel Czirban On or about June 20, 2015 - July 26, 2016, in the County of Monterey, the crime of FAILURE TO COLLECT, ACCOUNT FOR, OR PAY OVER TAXES in violation of U121 18.5, a FELONY, was committed by IAN NATHANIEL CZIRBAN, in that IAN NATHANIEL CZIRBAN, who willfully and unlawfully, as required by this code, fail to collect, account for, and/or pay over, any tax or amount required to be withheld, or truthfully account for and pay over this tax or amount to wit: Employment Development Department Payroll Tax Reports. Count 7 Labor Code Failure to Secure Payment of Workers' Compensation i Insurance - MISDEMEANOR as to Ian Nathaniel Czirban On or about July 26, 2016, in the County of Monterey, the crime of FAILURE TO SECURE PAYMENT OF COMPENSATION INSURANCE in violation of Labor Code a MISDEMEANOR, was committed by IAN NATHANIEL CZIRBAN, in that IAN NATHANIEL CZIRBAN, who did willfully, knowingly, and unlawfully fail to secure the payment of workers? compensation insurance as required by Article I of the California Labor Code (commencing with Section 3700). l/ Criminal Complaint DA File No.: 839288 District Attorney, County of Monterey Page 3 of 4 43mm this April 13, 2017, in the County of Monterey, I certify and declare under penalty of perjury that the foregoing is true and correct. DEAN D. FLIPPO District Attorney By: Carol Reed Deputy District Attorney Pursuant to Penal Code Section 1054.5 the People are hereby informally requesting that defendant(s) and his or her attorney provide to the People the discovery required by Penal Code Section 1054.3. This is a continuing request pursuant to the provisions of Penal Code Section 1054.7. NOTICE TO ATTORNEY The materials accompanying this notice may include information about witnesses which is disclosed to you pursuant to Penal Code Section 1054.2, which reads as follows: ?No attorney may disclose or permit to be disclosed to a defendant, members of the defendant?s family or anyone else, the address or telephone number of a victim or Witness whose name is disclosed to the attorney pursuant to subdivision Section 1054.1 unless speci?cally permitted to do so by the Court after a hearing and showing of good cause.? Willful Violation of this subdivision by an attorney is a misdemeanor. For purposes of this section, all names included in the attached reports are deemed to be witnesses pursuant to subdivision of Section 1054.1. For a list of law enforcement agencies that have agreed to participate in the DDA Brady Protocol, please View the Monterey County DA Website at: Criminal Complaint DA File No.: 839288 I District Attorney, County of Monterey Page 4 of 4