26 27 28 an ECERRA El 31 ?eggs WK, Attorney General of i? 1.. i 3% JAMES P. ROOT W3 Senior Assistant Attorney Genera-11.5 $5;th ml? MAGGY -- 1 .1 Supervising Deputy Attorney General ?1 - ,1 anti. ee sea DAWD C. BASS 51,, 1 .. -W. Deputy Attorney (Jeneral State Bar No. 296380 1300 I Street, Suite 1.25 PO. Box 944255 Sacramento, CA 94244~2550 Telephone: (91.6) 21051249 Fax: (91.6) 32223618 the People ofthe State ofC?aZifmw/zia COURT OF 'li?l?llii OF AND FOR "ii-ll}: OU NTY OF ONTRA COSTA THE PEOPLE OF THE STATE OF Case No. CAIJFORNEA, Plaintiffs, FELONY COMPLAINT MARK. WETERSON, Defendant. The Attorney General of the State of California hereby accuses Defendant, MARK PEPERSON, of the following charges: COUNT ONE On or about January 3 20l2, in the County of Contra Costa, the crime of PERJURY, in Violation ofPenal Code section t. 1.8, a Felony, was committed by MARK PETERSON, who did willfully and unlawfully, under penalty of perjury, state as true any material matter which he knew to be false, to wit: falsely state on California Form 460, Campaign Disclosure Statement, that the contents therein were true when, in tact, he knew they were not. Complaint COUNT TWO On or about August 3 l, 2012, in the County of Contra Costa, the crime of PERJURY, in violation of Penal Code section 1. 18, a Felony, was committed by MARK PETERSON, who did willfully and unlawfully, under penalty of perjury, state as true any material matter which he knew to be false, to wit: falsely state on California Form 460, Campaign Disclosure Statement, that the contents therein were true when, in fact, he knew they were not. OUNT On or about March 4, 2013, in the County of Contra Costa, the crime of PERJURY, in Violation of Penal Code section 1 '18, a lielony, was committed by MARK. who did willfully and unlawfully, under penalty of perjury, state as true any material matter which he knew to be false, to wit: falsely state on California Form 460, Campaign Disclosure Statement, that the contents therein were true when, in fact, he knew they were not. CO FOUR On or about July 31 2013, in the County of Contra Costa, the crime of PERJURY, in Violation of Penal Code section 8 a Felony, was committed by MARK who did. willfully and unlawfully, under penalty ofperjury, state as true any material matter which he knew to be false, to wit: falsely state on California Form 460, Campaign. Disclosure Statement, that the contents therein were true when, in fact, he knew they were not. COUNT FIVE On or about January 31, 20M, in the County of Contra Costa, the crime of PERJURY, in Violation of Penal Code section l. l8, a Felony, was committed by MARK PETERSON, who did willfully and unlawfully, under penalty of perjury, state as true any material matter which he knew to be false, to wit: falsely state on California Form 460, Campaign Disclosure Statement, that the contents therein were true when, in fact, he knew they were not. is.) Complaint COUNT SEX On or about April 8, 2014, in the County of Contra Costa, the crime of PERJURY, in violation of Penal Code section 1 l. 8, a Felony, was committed by MARK PETERSON, who did willfully and unlawfully, underpenalty oifperjury, state as true any material matter which. he knew to be false, to wit: falsely state on California Form 460, Campaign Disclosure Statement, that the contents therein were true when, in fact, he knew they were not. COUNT SEVEN On or about May 26, 201.4, in the County of Contra Costa, the crime of in Violation of'Penal Code section l. 1. 8, a Felony, was committed by MARK PIETIERSON, who did. willfully and unlawfully, under penalty of perjury, state as true any material matter which he knew to be false, to wit: falsely state on (Lialifornia Form 4'60, Campaign Disclosure Statement, "that the contents therein were true when, in fact, he knew they were not. COUNT On. or about July 31, 2014-, in the County of Contra Costa, the crime of PERJURY, in violation of Penal Code section 18, a Felony, was committed by MARK PETERSON, who did willfully and unlawfully, under penalty of perjury, state as true any .material matter which he knew to be false, to wit: falsely state on California 1.33 orm 460, Campaign Disclosure Statement, that the contents therein were true when, in fact, he knew they were not. NINE On or about February 15, 2015, in the County of Contra Costa, the crime of PERJURY, in violation of Penal Code section 1 18, a Felony, was committed by MARK who did willfully and unlawfully, under penalty of perjury, state as true any material matter which he knew to be false, to wit: falsely state on California Form 460, Campaign Disclosure Statement, that the contents therein were true when, in fact, he knew they were not. Complaint Ix.) La) 26 28 COUNT On or about July 29, 2015, in the County of Contra Costa, the crime of PERJURY, in violation of Penal Code section 18, a li?elony, was committed by MARK who did willfully and under penalty of perjury, state as true any material matter which he knew to be 'l?alse, to wit: falsely state on Caliil'ornia Form 460, Campaign Disclosure Statement, that the contents therein were true when, in tact, he knew they were not. connr smitten On or about March 28, 2014, in the County of Contra Costa, the crime of PERJURY, in violation ol?Penal Code section 3 18, a. 15*? elony, was committed. by MARK who did willfully and unlawfully, under penalty of perjury, state as tree any material matter which he knew to be false, to wit: falsely state on California Form. 700, Statement of Economic Interest, that the contents therein were true when, in fact, he knew they were not. On or about March 31, 20 5, in the County of Contra Costa, the crime of in violation of Penal. Code section 1 18, a 1'3 elony, was committed by MARK who did willfully and unlawfully, under penalty olj?perjury, state as true any material matter which he knew to be false, to wit: :lialsely state on California Form 700, Statement of Economic Interest, that the contents therein were true when, in fact, he knew they were not. COUNT On and between January l. 201 1., and October 31, 2015, in the County of Contra. Costa, the defendant, MARK lE?lii'l?l?l'RSON committed the crime of GRAND in Violation of RENAL CODE section 487(a) in that while defendant MARK PETERSON was an agent, servant, or employee of the FOR 2014'? campaign committee, defendant did unlawfully take the PETERSON FOR A'lwlORNliiY' 201. campaign committee money and personal property which aggregates to a value exceeding Nine li?i'l?ty Dollars to wit $66,372, a felony. 4 Complaint. I Sentence Enhancement (Penal Code section. It is further alleged that it} the commission of the offense alleged in count i. 3, defendant MARK PETERSON, with the intent to do so and. pursuant to a common scheme or plan, tools: and property of a value exceeding sixtyw'liive thousand dollars Within the meaning oft-)enal Code section SPECIAL ALLEGATEON Statute of Limitations - Discovery Within Four Years (Penal code, 803(c)) Law enforcement officials discovered the crimes alleged Within four years of the filing of this complaint. (Pen. Code, ?803, In a letter dated October 7, 2015 from the Franchise Tax Board Defendant Mark Peterson received notice that his committee had been selected for a random FTB audit, In January 0172016, Defendant self-?disclosed to the air Political Practices Commission that he made personal expenditures with campaign tends between 201 1 and 2015. Thus, discovery of the crimes alleged occurred after October 7, 2015. verity under information and belief, pursuant to Penal Code section 806, that the 'liorgoing is true and correct. Dated: June 13, 2017 Respectfully Submitted, XAVEER Attorney General of California MAGGY KRELL, Supervising Deputy Attorney General DAVID C. BASS Deputy Attorney General the People office State of California Complaint