IND CATHERINE CORTEZ MASTO 2 JOHN P. KELLEHER 3 · The undersigned, CATHERINE CORTEZ MASTO,...

IND CATHERINE CORTEZ MASTO Attorney General JOHN P. KELLEHER Assistant Chief Deputy Attorney General Nevada Bar No. 005387 702-486-3396 ROBERT G. GIUNTA Senior Deputy Attorney General Nevada Bar No. 1229 702-486-3199 555 E. Washington Avenue, #3900 Las Vegas, Nevada 89101 Attorneys for Plaintiff, State of Nevada

DISTRICT COURT

CLARK COUNTY, NEVADA STATE OF NEVADA, ) ) Plaintiff, ) CASE NO. : )

vs. ) DEPT. NO.: ) GARY TRAFFORD, ) GERRI SHEPPARD )

) DEFENDANTS )

INDICTMENT

The undersigned, CATHERINE CORTEZ MASTO, Attorney General of the State of

Nevada, by and through her Deputies, JOHN P. KELLEHER, Chief Deputy Attorney General

and ROBERT G. GIUNTA, Senior Deputy Attorney General, under penalty of perjury, and

within their knowledge, information and belief, complain and charge that the above named

Defendants, GARY TRAFFORD, (hereinafter “TRAFFORD”) has committed the offenses of

One Hundred Two (102) Counts of NOTARIZATION OF SIGNATURE OF PERSON NOT IN

PRESENCE OF NOTARY PUBLIC, (AID AND ABET), a gross misdemeanor in violation of

NRS 240.155; One Hundred Two (102) Counts of OFFERING FALSE INSTRUMENTS FOR

FILING OR RECORDING; a category C felony in violation of NRS 239.330; and One Hundred

Two (102) Counts of FALSE CERTIFICATION ON CERTAIN INSTRUMENTS (AID and

ABET); a category D felony in violation of NRS 205.120; and GERRI SHEPPARD (hereinafter

“SHEPPARD”) has committed the offenses of One Hundred (100) Counts of NOTARIZATION

OF SIGNATURE OF PERSON NOT IN PRESENCE OF NOTARY PUBLIC, (AID AND

ABET), a gross misdemeanor in violation of NRS 240.155; One Hundred (100) Counts of

OFFERING FALSE INSTRUMENTS FOR FILING OR RECORDING; a category C felony in

violation of NRS 239.330; and One Hundred (100) Counts of FALSE CERTIFICATION ON

CERTAIN INSTRUMENTS (AID and ABET); a category D felony in violation of NRS 205.120.

Said aforementioned crimes constitute TECHNOLOGICAL CRIMES as defined in NRS

205A.030 and property which was derived from, realized through, or used or intended for use

in the course of a technological crime is subject to forfeiture pursuant to NRS 179.1219.

Said aforementioned crimes have been committed within Clark County, State of

Nevada in the following manner:

COUNT 1

NOTARIZATION OF SIGNATURE OF PERSON NOT IN PRESENCE NOTARY PUBLIC (AID & ABET)

GROSS MISDEMEANOR NRS 240.155(2)

On or about September 25, 2008, Defendant TRAFFORD, within Clark County, State of

Nevada, did then and there willfully aid and abet in the notarization of an individual’s signature,

when said person whose signature was being notarizing was not in the notary’s presence, to

On or about September 25, 2008, Defendant TRAFFORD within Clark County, State of

Nevada, planned, directed, or arranged to have TRACY LAWRENCE, (hereinafter

“LAWRENCE”), a notary public appointed by the Nevada Secretary of State, and authorized to

take proof or acknowledgment of an instrument, to forge and notarize his signature on a

NOTICE OF DEFAULT AND ELECTION TO SELL UNDER DEED OF TRUST, Instrument No.

0003798 of Official Records filed in the Office of the County Recorder of Clark County,

Nevada dated September 25, 2008, when Defendant TRAFFORD was not in Defendant’s

presence and further never signed said document. These actions were performed in a

secretive manner in order that the false documents be given full legal effect and that this

criminal activity not be discovered. This activity was discovered on or about December of

All of which constitutes the crime of NOTARIZATION OF SIGNATURE OF PERSON

NOT IN PRESENCE NOTARY PUBLIC, a violation of NRS 240.155, a gross misdemeanor.

COUNT 2

OFFERING A FALSE INSTRUMENT FOR FILING OR RECORDING Felony NRS 239.330

On or about September 25, 2008, Defendant TRAFFORD did, in the County of Clark,

State of Nevada, then and there, knowingly and feloniously, cause to be offered for filing in a

public office, a false and/or forged instrument, which instrument, if genuine, might be filed,

registered or recorded in a public office under the law of the State of Nevada, to wit:

On or about September 25, 2008, Defendant TRAFFORD, within Clark County, State

of Nevada, either directly or through an agent or employee, caused to be offered for filing, a

0003798 of Official Records with the Office of the County Recorder of Clark County, Nevada

dated September 25, 2008. Said document was forged in that it purported to be signed by

Defendant TRAFFORD, as the agent for the beneficiary of the property listed in said

instrument, when in truth and in fact Defendant TRAFFORD did not sign said instrument, as

Defendant TRAFFORD well knew. These actions were performed in a secretive manner in

order that the false documents be given full legal effect and that this criminal activity not be

discovered. This activity was discovered on or about December of 2010.

All of which constitutes the crime of OFFERING A FALSE INSTRUMENT FOR FILING

OR RECORDING, a violation of NRS 239.330, a category C felony.

COUNT 3

FALSE CERTIFICATE TO CERTAIN INSTRUMENTS (AID & ABET)

Felony NRS 205.120

On or about September 25, 2008, Defendant TRAFFORD, within the County of Clark,

State of Nevada, did then and there plan, direct, and arrange to have a person authorized to

take proof or acknowledgment of an instrument which by law may be recorded, willfully certify

falsely that the execution of the instrument was acknowledged by a party thereto or that the

execution thereof was proved, to wit:

On or about September 25, 2008, Defendant TRAFFORD planned, directed, and

arranged to have TRACY LAWRENCE, (hereinafter “LAWRENCE”), a notary public appointed

by the Nevada Secretary of State, and authorized to take proof or acknowledgment of an

instrument, to forge and willfully certify falsely that the execution of this instrument was

acknowledged by her signature, on a document entitled NOTICE OF DEFAULT AND

ELECTION TO SELL UNDER DEED OF TRUST, Instrument No. 0003798 of Official Records

filed in the Office of the County Recorder of Clark County, Nevada dated September 25, 2008.

These actions were performed in a secretive manner in order that the false documents

be given full legal effect and that this criminal activity not be discovered. This activity was

discovered on or about December of 2010.

All of which constitutes the crime of FALSE CERTIFICATE TO CERTAIN

INSTRUMENTS a category D felony pursuant to NRS 205.120.

COUNT 4

On or about December 7, 2005, Defendant SHEPPARD, within Clark County, State of

On or about December 7, 2005, Defendant SHEPPARD within Clark County, State of

Nevada, planned, directed, or arranged to have MEGHAN BLOECKER, (hereinafter

“BLOECKER”), a notary public appointed by the Nevada Secretary of State, and authorized to

take proof or acknowledgment of an instrument, to forge and notarize her signature on a

Nevada dated December 7, 2005, when Defendant SHEPPARD was not in Defendant’s

COUNT 5

OFFERING A FALSE INSTRUMENT FOR FILING OR RECORDING (AID &ABET)

Felony NRS 239.330

On or about December 7, 2005, Defendant SHEPPARD, in the County of Clark, State

of Nevada, then and there, knowingly and feloniously, cause to be offered for filing in a public

office, a false and/or forged instrument, which instrument, if genuine, might be filed, registered

or recorded in a public office under the law of the State of Nevada, to wit:

Nevada, either directly or through an agent or employee, caused to be offered for filing, a

dated December 7, 2005. Said document was forged in that it purported to be signed by

Defendant SHEPPARD as the agent for the beneficiary of the property listed in said

instrument, when in truth and in fact Defendant SHEPPARD did not sign said instrument, as

Defendant SHEPPARD well knew. These actions were performed in a secretive manner in

COUNT 6

FALSE CERTIFICATE TO CERTAIN INSTRUMENTS (AID &ABET) FELONY NRS 205.120

On or about December 7, 2005, Defendant SHEPPARD, within the County of Clark,

On or about December 7, 2005, Defendant SHEPPARD planned, directed, and

arranged to have MEGHAN BLOECKER, (hereinafter “BLOECKER”), a notary public appointed

filed in the Office of the County Recorder of Clark County, Nevada dated December 7, 2005.

These actions were performed in a secretive manner in order that the false documents be

given full legal effect and that this criminal activity not be discovered. This activity was

COUNT 7

On or about February 4, 2005, Defendant SHEPPARD, within Clark County, State of

On or about February 4, 2005, Defendant SHEPPARD within Clark County, State of

Nevada dated February 4, 2005, when Defendant SHEPPARD was not in Defendant’s

COUNT 8

Felony NRS 239.330

On or about February 7, 2005 Defendant SHEPPARD, in the County of Clark, State of

Nevada, then and there, knowingly and feloniously, cause to be offered for filing in a public

dated February 7, 2005. Said document was forged in that it purported to be signed by

COUNT 9

FALSE CERTIFICATE TO CERTAIN INSTRUMENTS (AID & ABET) Felony NRS 205.120

On or about February 4, 2005, Defendant SHEPPARD, within the County of Clark,

On or about February 4, 2005, Defendant SHEPPARD planned, directed, and arranged

to have MEGHAN BLOECKER, (hereinafter “BLOECKER”), a notary public appointed by the

Nevada Secretary of State, and authorized to take proof or acknowledgment of an instrument,

to forge and willfully certify falsely that the execution of this instrument was acknowledged by

her signature, on a document entitled NOTICE OF DEFAULT AND ELECTION TO SELL

UNDER DEED OF TRUST, Instrument No. 0001816 of Official Records filed in the Office of

the County Recorder of Clark County, Nevada dated February 7, 2005. These actions were

performed in a secretive manner in order that the false documents be given full legal effect

and that this criminal activity not be discovered. This activity was discovered on or about

December of 2010.

COUNT 10

NOTARIZATION OF SIGNATURE OF PERSON NOT IN PRESENCE NOTARY PUBLIC

(AID & ABET) GROSS MISDEMEANOR NRS 240.155(2)

Nevada dated February 8, 2005, when Defendant SHEPPARD was not in Defendant’s

COUNT 11

Felony NRS 239.330

On or about February 8, 2005, Defendant SHEPPARD, in the County of Clark, State of

discovered. This activity was discovered on or about December of 2010

COUNT 12

to have MEGHAN BLOECKER, (hereinafter “BLOECKER”), a notary public appointed by the

December of 2010.

COUNT 13

On or about June 29, 2005, Defendant SHEPPARD, within Clark County, State of

On or about June 29, 2005, Defendant SHEPPARD within Clark County, State of

Nevada dated June 29, 2005 when Defendant SHEPPARD was not in Defendant’s presence

and further never signed said document. These actions were performed in a secretive

manner in order that the false documents be given full legal effect and that this criminal

activity not be discovered. This activity was discovered on or about December of 2010

COUNT 14

Felony NRS 239.330

On or about June 29, 2005 Defendant SHEPPARD, in the County of Clark, State of

dated June 29, 2005. Said document was forged in that it purported to be signed by

COUNT 15

On or about June 29, 2005, Defendant SHEPPARD, within the County of Clark, State

of Nevada, did then and there plan, direct, and arrange to have a person authorized to take

proof or acknowledgment of an instrument which by law may be recorded, willfully certify

On or about June 29, 2005, Defendant SHEPPARD planned, directed, and arranged to

have MEGHAN BLOECKER, (hereinafter “BLOECKER”), a notary public appointed by the

the County Recorder of Clark County, Nevada dated June 29,2005. These actions were

December of 2010.

COUNT 16 NOTARIZATION OF SIGNATURE OF PERSON NOT IN PRESENCE NOTARY PUBLIC

On or about July 9, 2007, Defendant TRAFFORD, within Clark County, State of

On or about July 9, 2007, Defendant TRAFFORD within Clark County, State of Nevada,

planned, directed, or arranged to have TRACY LAWRENCE, (hereinafter “LAWRENCE”), a

notary public appointed by the Nevada Secretary of State, and authorized to take proof or

acknowledgment of an instrument, to forge and notarize his signature on a NOTICE OF

DEFAULT AND ELECTION TO SELL UNDER DEED OF TRUST, Instrument No. 0004247 of

Official Records filed in the Office of the County Recorder of Clark County, Nevada dated July

9, 2007 when Defendant TRAFFORD was not in Defendant’s presence and further never

signed said document. These actions were performed in a secretive manner in order that the

false documents be given full legal effect and that this criminal activity not be discovered.

This activity was discovered on or about December of 2010.

COUNT 17

OFFERING A FALSE INSTRUMENT FOR FILING OR RECORDING

(AID &ABET) Felony NRS 239.330

On or about July 9, 2007, Defendant TRAFFORD did, in the County of Clark, State of

dated July 9, 2007. Said document was forged in that it purported to be signed by Defendant

TRAFFORD, as the agent for the beneficiary of the property listed in said instrument, when in

truth and in fact Defendant TRAFFORD did not sign said instrument, as Defendant

TRAFFORD well knew. These actions were performed in a secretive manner in order that the

COUNT 18

On or about July 9, 2007, Defendant TRAFFORD, within the County of Clark, State of

Nevada, did then and there plan, direct, and arrange to have a person authorized to take proof

or acknowledgment of an instrument which by law may be recorded, willfully certify falsely that

the execution of the instrument was acknowledged by a party thereto or that the execution

thereof was proved, to wit:

On or about July 9, 2007, Defendant TRAFFORD planned, directed, and arranged to

have TRACY LAWRENCE, (hereinafter “LAWRENCE”), a notary public appointed by the

his signature, on a document entitled NOTICE OF DEFAULT AND ELECTION TO SELL

the County Recorder of Clark County, Nevada dated July 9, 2007. These actions were

December of 2010.

On or about August 2, 2007, Defendant TRAFFORD, within Clark County, State of

On or about August 2, 2007, Defendant TRAFFORD within Clark County, State of

Nevada dated August 2, 2007, when Defendant TRAFFORD was not in Defendant’s presence

COUNT 20

Felony NRS 239.330

On or about August 2, 2007, Defendant TRAFFORD did, in the County of Clark, State

dated August 2, 2007. Said document was forged in that it purported to be signed by

COUNT 21

On or about August 2, 2007, Defendant TRAFFORD, within the County of Clark, State

On or about August 2, 2007, Defendant TRAFFORD planned, directed, and arranged to

the County Recorder of Clark County, Nevada dated August 2, 2007. These actions were

December of 2010.

On or about May 12, 2008, Defendant TRAFFORD, within Clark County, State of

On or about May 12, 2008, Defendant TRAFFORD within Clark County, State of

Nevada dated May 12, 2008, when Defendant TRAFFORD was not in Defendant’s presence

COUNT 23

Felony NRS 239.330

On or about May 12, 2008, Defendant TRAFFORD did, in the County of Clark, State of

dated May 12, 2008. Said document was forged in that it purported to be signed by

COUNT 24

FALSE CERTIFICATE TO CERTAIN INSTRUMENTS (AID &ABET)

FELONY NRS 205.120

On or about May 12, 2008, Defendant TRAFFORD, within the County of Clark, State of

On or about May 12, 2008, Defendant TRAFFORD planned, directed, and arranged to

the County Recorder of Clark County, Nevada dated May 12, 2008. These actions were

December of 2010.

COUNT 25

On or about July 22, 2008, Defendant TRAFFORD within Clark County, State of

Nevada dated July 22, 2008 when Defendant TRAFFORD was not in Defendant’s presence

COUNT 26

Felony NRS 239.330

All of which constitutes the crime of OFFERING A FALSE INSTRUMENT FOR FILING OR

RECORDING, a violation of NRS 239.330, a category C felony.

COUNT 27

December of 2010.

On or about December 2, 2005, Defendant TRAFFORD, within Clark County, State of

On or about December 2, 2005, Defendant TRAFFORD within Clark County, State of

“LAWRENCE”) a notary public appointed by the Nevada Secretary of State, and authorized to

Nevada dated December 2, 2005, when Defendant TRAFFORD was not in Defendant’s

COUNT 29

Felony NRS 239.330

On or about December 2, 2005, Defendant TRAFFORD did, in the County of Clark,

COUNT 30

On or about December 2, 2005, Defendant TRAFFORD, within the County of Clark, State of

On or about, December 2, 2005, Defendant TRAFFORD planned, directed, and

arranged to have TRACY LAWRENCE, (hereinafter “LAWRENCE”) , a notary public appointed

filed in the Office of the County Recorder of Clark County, Nevada dated December 2, 2005

On or about April 12, 2006, Defendant TRAFFORD, within Clark County, State of

On or about April 12, 2006, Defendant TRAFFORD within Clark County, State of

Nevada dated April 12, 2006, when Defendant TRAFFORD/SHEPPARD was not in

Defendant’s presence and further never signed said document. These actions were

December of 2010.

COUNT 32

Felony NRS 239.330

On or about April 12, 2006, Defendant TRAFFORD did, in the County of Clark, State of

dated April 12, 2006. Said document was forged in that it purported to be signed by

COUNT 33

On or about April 12, 2006, Defendant TRAFFORD, within the County of Clark, State of

On or about, April 12, 2006, Defendant TRAFFORD planned, directed, and arranged to

the County Recorder of Clark County, Nevada dated April 12, 2006. These actions were

December of 2010.

COUNT 34

Nevada dated July 23, 2007, when Defendant TRAFFORD was not in Defendant’s presence

COUNT 35

COUNT 36

On or about, July 23, 2007, Defendant TRAFFORD planned, directed, and arranged to

have TRACY LAWRENCE, (hereinafter “LAWRENCE”) , a notary public appointed by the

December of 2010.

On or about February 8, 2008, Defendant TRAFFORD, within Clark County, State of

On or about February 8, 2008, Defendant TRAFFORD within Clark County, State of

“LAWRENCE”) , a notary public appointed by the Nevada Secretary of State, and authorized

to take proof or acknowledgment of an instrument, to forge and notarize her signature on a

Nevada dated February 8, 2008 when Defendant TRAFFORD was not in Defendant’s

COUNT 38

Felony NRS 239.330

On or about February 8, 2008, Defendant TRAFFORD did, in the County of Clark,

COUNT 39

On or about February 8, 2008, Defendant TRAFFORD, within the County of Clark,

On or about, February 8, 2008, Defendant TRAFFORD planned, directed, and arranged

to have TRACY LAWRENCE, (hereinafter “LAWRENCE”) , a notary public appointed by the

December of 2010.

COUNT 40

On or about March 20, 2007, Defendant TRAFFORD, within Clark County, State of

On or about March 20, 2007, Defendant TRAFFORD within Clark County, State of

Nevada dated March 20, 2007, when Defendant TRAFFORD was not in Defendant’s

COUNT 41

Felony NRS 239.330

On or about March 20, 2007, Defendant TRAFFORD did, in the County of Clark, State

dated March 20, 2007. Said document was forged in that it purported to be signed by

COUNT 42

On or about March 20, 2007, Defendant TRAFFORD, within the County of Clark, State

On or about, March 20, 2007, Defendant TRAFFORD planned, directed, and arranged

to have TRACY LAWRENCE, (hereinafter “LAWRENCE”), a notary public appointed by the

the County Recorder of Clark County, Nevada dated March 20, 2007. These actions were

December of 2010.

“LAWRENCE”), a notary public appointed by the Nevada Secretary of State, and authorized

to take proof or acknowledgment of an instrument, to forge and notarize his signature on a

COUNT 44

Felony NRS 239.330

On or about March 29, 2007, Defendant TRAFFORD/SHEPPARD did, in the County of

Clark, State of Nevada, then and there, knowingly and feloniously, cause to be offered for

filing in a public office, a false and/or forged instrument, which instrument, if genuine, might be

filed, registered or recorded in a public office under the law of the State of Nevada, to wit:

COUNT 45

On or about, March 29,2007, Defendant TRAFFORD planned, directed, and arranged

December of 2010.

INSTRUMENTS a category D felony pursuant to NRS 205.120

COUNT 46

Nevada dated March 29,2007, when Defendant TRAFFORD was not in Defendant’s presence

COUNT 47

Felony NRS 239.330

dated May 1, 2007. Said document was forged in that it purported to be signed by Defendant

COUNT 48

On or about , May 1, 2007, Defendant TRAFFORD planned, directed, and arranged to

have TRACY LAWRENCE,(hereinafter “LAWRENCE”), a notary public appointed by the

December of 2010.

COUNT 49

COUNT 50

Felony NRS 239.330

On or about May 31, 2007 Defendant TRAFFORD did, in the County of Clark, State of

COUNT 51

December of 2010.

COUNT 52

On or about June 28, 2007, Defendant TRAFFORD, within Clark County, State of

On or about June 28, 2007, Defendant TRAFFORD within Clark County, State of

Nevada dated June 28, 2007, when Defendant TRAFFORD was not in Defendant’s presence

COUNT 53

Felony NRS 239.330

On or about June 28, 2007 Defendant TRAFFORD did, in the County of Clark, State of

COUNT 54

FALSE CERTIFICATE TO CERTAIN INSTRUMENTS (AID &ABET) FELONY NRS 205.120.

On or about June 28, 2007, Defendant TRAFFORD, within the County of Clark, State

On or about June 28, 2007, Defendant TRAFFORD planned, directed, and arranged to

the County Recorder of Clark County, Nevada dated June 28, 2007. These actions were

December of 2010.

COUNT 55

Nevada dated July 31,2007, when Defendant TRAFFORD was not in Defendant’s presence

COUNT 56

Felony NRS 239.330

On or about July 31, 2007 Defendant TRAFFORD did, in the County of Clark, State of

COUNT 57

On or about, July 31,2007, Defendant TRAFFORD planned, directed, and arranged to

the County Recorder of Clark County, Nevada dated July 31,2007, These actions were

December of 2010.

COUNT 58

COUNT 59

COUNT 60

acknowledged by his signature, on a document entitled NOTICE OF DEFAULT AND

filed in the Office of the County Recorder of Clark County, Nevada dated September 28,2007.

COUNT 61

On or about October 2, 2007, Defendant TRAFFORD, within Clark County, State of

On or about October 2, 2007, Defendant TRAFFORD within Clark County, State of

Nevada dated October 2, 2007 when Defendant TRAFFORD was not in Defendant’s

COUNT 62

Felony NRS 239.330

On or about October 2, 2007, Defendant TRAFFORD did, in the County of Clark, State

dated October 2, 2007. Said document was forged in that it purported to be signed by

COUNT 63

On or about October 2, 2007, Defendant TRAFFORD, within the County of Clark, State

On or about October 2, 2007, Defendant TRAFFORD planned, directed, and arranged

the County Recorder of Clark County, Nevada dated October 2, 2007. These actions were

December of 2010.

COUNT 64

Nevada dated October 29, 2007, when Defendant TRAFFORD was not in Defendant’s

COUNT 65

Felony NRS 239.330

On or about October 29, 2007, Defendant TRAFFORD did, in the County of Clark,

COUNT 66

On or about October 29, 2007, Defendant TRAFFORD, within the County of Clark,

December of 2010.

COUNT 67

On or about November 2, 2007, Defendant TRAFFORD, within Clark County, State of

On or about November 2, 2007, Defendant TRAFFORD within Clark County, State of

Nevada dated November 2, 2007, when Defendant TRAFFORD was not in Defendant’s

COUNT 68

Felony NRS 239.330

On or about November 2, 2007, Defendant TRAFFORD did, in the County of Clark,

dated November 2, 2007. Said document was forged in that it purported to be signed by

instrument, when in truth and in fact Defendant TRAFFORD/SHEPPARD did not sign said

instrument, as Defendant TRAFFORD well knew. These actions were performed in a

COUNT 69

On or about November 2, 2007, Defendant TRAFFORD, within the County of Clark,

On or about November 2, 2007, Defendant TRAFFORD planned, directed, and

filed in the Office of the County Recorder of Clark County, Nevada dated November 2, 2007.

COUNT 70

On or about December 21,2007, Defendant TRAFFORD within Clark County, State of

Nevada dated December 21,2007, when Defendant TRAFFORD was not in Defendant’s

COUNT 71

Felony NRS 239.330

On or about December 21, 2007 Defendant TRAFFORD did, in the County of Clark,

COUNT 72

On or about December 21, 2007, Defendant TRAFFORD, within the County of Clark,

On or about December 21, 2007, Defendant TRAFFORD planned, directed, and

arranged to have TRACY LAWRENCE (hereinafter “LAWRENCE”), a notary public appointed

filed in the Office of the County Recorder of Clark County, Nevada dated December 21,2007.

COUNT 73

On or about January 10, 2008, Defendant TRAFFORD, within Clark County, State of

On or about January 10, 2008, Defendant TRAFFORD within Clark County, State of

Nevada dated January 10, 2008, when Defendant TRAFFORD was not in Defendant’s

COUNT 74

On or about January 10, 2008, Defendant TRAFFORD did, in the County of Clark,

dated January 10, 2008. Said document was forged in that it purported to be signed by

COUNT 75

On or about January 10, 2008, Defendant TRAFFORD, within the County of Clark,

On or about January 10, 2008, Defendant TRAFFORD planned, directed, and arranged

the County Recorder of Clark County, Nevada dated January 10, 2008. These actions were

December of 2010.

COUNT 76

COUNT 77

Felony NRS 239.330

COUNT 78

FELONY NRS 205.120

to have TRACY LAWRENCE (hereinafter “LAWRENCE”), a notary public appointed by the

the County Recorder of Clark County, Nevada dated January 31,2008. These actions were

December of 2010.

COUNT 79

Nevada dated February 1, 2008, when Defendant TRAFFORD was not in Defendant’s

COUNT 80

OFFERING A FALSE INSTRUMENT FOR FILING OR RECORDING (AID & ABET)

Felony NRS 239.330

COUNT 81

On or about February1, 2008, Defendant TRAFFORD, within the County of Clark, State

On or about February 1, 2008 , Defendant TRAFFORD planned, directed, and arranged

December of 2010.

COUNT 82

On or about February 29, 2008 February 1, 2008, Defendant TRAFFORD, within Clark

County, State of Nevada, did then and there willfully aid and abet in the notarization of an

individual’s signature, when said person whose signature was being notarizing was not in the

notary’s presence, to wit;

COUNT 83

Felony NRS 239.330

COUNT 84

On or about February 29, 2008, Defendant TRAFFORD planned, directed, and

filed in the Office of the County Recorder of Clark County, Nevada dated February 29, 2008.

COUNT 85

COUNT 86

COUNT 87

On or about March 20, 2008, Defendant TRAFFORD planned, directed, and arranged

the County Recorder of Clark County, Nevada dated March 20, 2008 . These actions were

December of 2010.

COUNT 88

Nevada dated April 15, 2008, when Defendant TRAFFORD was not in Defendant’s presence

COUNT 89

Felony NRS 239.330

COUNT 90

On or about April 15, 2008, Defendant TRAFFORD planned, directed, and arranged to

December of 2010.

COUNT 91

COUNT 92

Felony NRS 239.330

COUNT 93

the County Recorder of Clark County, Nevada dated April 23, 2008 . These actions were

December of 2010.

COUNT 94

COUNT 95

Felony NRS 239.330

COUNT 96

December of 2010.

COUNT 97

COUNT 98

Felony NRS 239.330

On or about June 3, 2008, Defendant TRAFFORD did, in the County of Clark, State of

dated June 3, 2008. Said document was forged in that it purported to be signed by Defendant

COUNT 99

On or about June 3, 2008, Defendant TRAFFORD, within the County of Clark, State of

the County Recorder of Clark County, Nevada dated June 3, 2008 . These actions were

December of 2010.

All of which constitutes the crime of FALSE CERTIFICATE TO CERTAIN INSTRUMENTS a

category D felony pursuant to NRS 205.120.

COUNT 100

Nevada dated July 28, 2008 when Defendant TRAFFORD was not in Defendant’s presence

activity not be discovered. This activity was discovered on or about December of 2010.

COUNT 101

Felony NRS 239.330

On or about July 28, 2008 Defendant TRAFFORD did, in the County of Clark, State of

COUNT 102

the County Recorder of Clark County, Nevada dated July 28, 2008 . These actions were

December of 2010.

COUNT 103

Nevada dated August 12, 2008, when Defendant TRAFFORD was not in Defendant’s

COUNT 104

On or about August 12, 2008, Defendant TRAFFORD, within Clark County, State of Nevada,

either directly or through an agent or employee, caused to be offered for filing, a NOTICE OF

Official Records with the Office of the County Recorder of Clark County, Nevada dated August

12, 2008. Said document was forged in that it purported to be signed by Defendant

COUNT 105

FELONY NRS 205.120

On or about August 12, 2008, Defendant TRAFFORD planned, directed, and arranged

December of 2010.

COUNT 106

COUNT 107

On or about August 27, 2008, Defendant TRAFFORD, within Clark County, State of Nevada,

Official Records with the Office of the County Recorder of Clark County, Nevada dated August

COUNT 108

December of 2010.

COUNT 109

NOT IN PRESENCE NOTARY PUBLIC, a violation of NRS 240.155, a Gross misdemeanor.

COUNT 110

Felony NRS 239.330

COUNT 111

filed in the Office of the County Recorder of Clark County, Nevada dated September 9, 2008 .

COUNT 112

COUNT 113

Felony NRS 239.330

COUNT 114

FELONY NRS 205.120

COUNT 115

COUNT 116

Felony NRS 239.330

COUNT 117

On or about October 2, 2008, Defendant TRAFFORD, within the County of Clark, State

December of 2010.

COUNT 118

COUNT 119

COUNT 120

December of 2010.

COUNT 121

On or about October 6, 2006, Defendant SHEPPARD, within Clark County, State of

On or about October 6, 2006, Defendant SHEPPARD within Clark County, State of

Nevada dated October 6, 2006, when Defendant SHEPPARD was not in Defendant’s

COUNT 122

On or about October 6, 2006, Defendant SHEPPARD did, in the County of Clark, State

Defendant SHEPPARD, as the agent for the beneficiary of the property listed in said

COUNT 123

On or about October 6, 2006, Defendant SHEPPARD, within the County of Clark, State

On or about October 6, 2006, Defendant SHEPPARD planned, directed, and arranged

December of 2010.

COUNT 124

On or about December 29, 2005, Defendant SHEPPARD within Clark County, State of

Nevada dated December 29, 2005, when Defendant SHEPPARD was not in Defendant’s

COUNT 125

Felony NRS 239.330

On or about December 29, 2005, Defendant SHEPPARD did, in the County of Clark,

COUNT 126

FELONY NRS 205.120

On or about December 29, 2005, Defendant SHEPPARD, within the County of Clark,

On or about December 29, 2005, Defendant SHEPPARD planned, directed, and

COUNT 127

On or about January 9, 2006, Defendant SHEPPARD, within Clark County, State of

On or about January 9, 2006, Defendant SHEPPARD within Clark County, State of

Nevada dated January 9, 2006, when Defendant SHEPPARD was not in Defendant’s

COUNT 128

Felony NRS 239.330

On or about January 9, 2006, Defendant SHEPPARD did, in the County of Clark, State

COUNT 129

FELONY NRS 205.120

On or about January 9, 2006, Defendant SHEPPARD, within the County of Clark, State

On or about January 9, 2006, Defendant SHEPPARD planned, directed, and arranged

December of 2010.

COUNT 130

Nevada dated January 26, 2006, when Defendant SHEPPARD was not in Defendant’s

COUNT 131

Felony NRS 239.330

On or about January 26, 2006, Defendant SHEPPARD did, in the County of Clark,

COUNT 132

On or about January 26, 2006, Defendant SHEPPARD, within the County of Clark,

December of 2010.

COUNT 133

NOT IN PRESENCE NOTARY PUBLIC, a violation of NRS 240.155, a gross Misdemeanor.

COUNT 134

COUNT 135

December of 2010.

COUNT 136

COUNT 137

Felony NRS 239.330

false documents be given full legal effect and that this criminal activity not be discovered. This

activity was discovered on or about December of 2010.

COUNT 138

December of 2010.

COUNT 139

Nevada dated June 20, 2006 when Defendant TRAFFORD was not in Defendant’s presence

COUNT 140

On or about June 20, 2006 DEFENDANT TRAFFORD did, in the County of Clark,

On or about June 20, 2006, Defendant TRAFFORD, within Clark County, State of Nevada,

Official Records with the Office of the County Recorder of Clark County, Nevada dated June

COUNT 141

FELONY NRS 205.120

December of 2010.

COUNT 142

Nevada, planned, directed, or arranged to have TRACY LAWRENCE (hereinafter

COUNT 143

Felony NRS 239.330

COUNT 144

COUNT 145

COUNT 146

Felony NRS 239.330

COUNT 147

FELONY NRS 205.120

On or about November 2, 2006, Defendant TRAFFORD planned, directed, and arranged

the County Recorder of Clark County, Nevada dated November 2, 2006. These actions were

December of 2010.

COUNT 148

COUNT 149

Felony NRS 239.330

COUNT 150

December of 2010.

COUNT 151

COUNT 152

COUNT 153

FELONY NRS 205.120

On or about August 14, 2007, Defendant TRAFFORD planned, directed, and arranged to have

TRACY LAWRENCE, (hereinafter “LAWRENCE”), a notary public appointed by the Nevada

Secretary of State, and authorized to take proof or acknowledgment of an instrument, to forge

and willfully certify falsely that the execution of this instrument was acknowledged by her

signature, on a document entitled NOTICE OF DEFAULT AND ELECTION TO SELL UNDER

DEED OF TRUST, Instrument No. 0003468 of Official Records filed in the Office of the

County Recorder of Clark County, Nevada dated August 14, 2007. These actions were

December of 2010.

COUNT 154

COUNT 155

COUNT 156

COUNT157

Nevada dated October 15, 2007 when Defendant TRAFFORD was not in Defendant’s

COUNT 158

Felony NRS 239.330

COUNT 159

FELONY NRS 205.120

December of 2010.

COUNT 160

COUNT 161

Felony NRS 239.330

COUNT 162

FELONY NRS 205.120

December of 2010.

COUNT 163

COUNT 164

Felony NRS 239.330

COUNT 165

December of 2010.

COUNT 166

COUNT 167

Felony NRS 239.330

DEFENDANT TRAFFORD well knew. These actions were performed in a secretive manner

in order that the false documents be given full legal effect and that this criminal activity not be

COUNT 168

COUNT 169

COUNT 170

Felony NRS 239.330

On or about December 3, 2007, DEFENDANT TRAFFORD did, in the County of Clark,

On or about December 3, 2007, DEFENDANT TRAFFORD, within Clark County, State

DEFENDANT TRAFFORD, as the agent for the beneficiary of the property listed in said

instrument, when in truth and in fact DEFENDANT TRAFFORD did not sign said instrument,

as DEFENDANT TRAFFORD well knew. These actions were performed in a secretive

COUNT 171

On or about December 3, 2007, Defendant TRAFFORD planned, directed, and arranged

the County Recorder of Clark County, Nevada dated December 3, 2007. These actions were

December of 2010.

COUNT 172

COUNT 173

COUNT 174

COUNT 175

COUNT 176

Felony NRS 239.330

On or about January 8, 2008, Defendant TRAFFORD did, in the County of Clark, State

COUNT 177

On or about January 8, 2008, DEFENDANT TRAFFORD, within the County of Clark,

December of 2010.

COUNT 178

COUNT 179

Felony NRS 239.330

COUNT 180

FELONY NRS 205.120

On or about January 22, 2008, DEFENDANT TRAFFORD, within the County of Clark,

December of 2010.

COUNT 181

COUNT 182

COUNT 183

On or about February 22, 2008, Defendant TRAFFORD planned, directed, and arranged

December of 2010.

COUNT 184

COUNT 185

Felony NRS 239.330

COUNT 186

On or about March 10, 2008, Defendant TRAFFORD planned, directed, and arranged to

have TRACY LAWRENCE (hereinafter “LAWRENCE”), a notary public appointed by the

December of 2010.

COUNT 187

COUNT 188

COUNT 189

December of 2010.

COUNT 190

and further never signed said document. These actions were performed in a secretive manner

COUNT 191

Felony NRS 239.330

dated April 7, 2008. Said document was forged in that it purported to be signed by Defendant

COUNT 192

December of 2010.

COUNT 193

COUNT 194

Felony NRS 239.330

COUNT 195

FELONY NRS 205.120

December of 2010.

COUNT 196

COUNT 197

Felony NRS 239.330

COUNT 198

December of 2010.

COUNT 199

COUNT 200

Felony NRS 239.330

COUNT 201

December of 2010.

COUNT 202

COUNT 203

Felony NRS 239.330

COUNT 204

December of 2010.

COUNT 205

On or about July 8, 2008, Defendant TRAFFORD within Clark County, State of Nevada,

planned, directed, or arranged to have TRACY LAWRENCE (hereinafter “LAWRENCE”), a

acknowledgment of an instrument, to forge and notarize her signature on a NOTICE OF

8, 2008, when Defendant TRAFFORD was not in Defendant’s presence and further never

COUNT 206

Felony NRS 239.330

COUNT 207

December of 2010.

COUNT 208

Nevada dated August 1, 2008, when Defendant TRAFFORD was not in Defendant’s presence

COUNT 209

Felony NRS 239.330

COUNT 210

FELONY NRS 205.120

On or about August 1, 2008, Defendant TRAFFORD planned, directed, and arranged to

December of 2010.

COUNT 211

COUNT 212

Felony NRS 239.330

COUNT 213

December of 2010.

COUNT 214

COUNT 215

Felony NRS 239.330

COUNT 216

FELONY NRS 205.120

COUNT 217

COUNT 218

COUNT 219

FELONY NRS 205.120

COUNT 220

COUNT 221

Felony NRS 239.330

COUNT 222

December of 2010.

COUNT 223

COUNT 224

Felony NRS 239.330

COUNT 225

FELONY NRS 205.120

December of 2010.

COUNT 226

COUNT 227

Felony NRS 239.330

COUNT 228

December of 2010.

COUNT 229

COUNT 230

Felony NRS 239.330

COUNT 231

FELONY NRS 205.120

December of 2010.

COUNT 232

COUNT 233

COUNT 234

COUNT 235

COUNT 236

Felony NRS 239.330

On or about January 3, 2006, Defendant TRAFFORD did, in the County of Clark, State

On or about January 3, 2006, Defendant TRAFFORD, within Clark County, State of Nevada,

Official Records with the Office of the County Recorder of Clark County, Nevada dated

January 3, 2006. Said document was forged in that it purported to be signed by Defendant

COUNT 237

On or about January 3, 2006, Defendant TRAFFORD, within the County of Clark, State

December of 2010.

COUNT 238

COUNT 239

Felony NRS 239.330

COUNT 240

FELONY NRS 205.120

December of 2010.

COUNT 241

COUNT 242

Felony NRS 239.330

COUNT 243

December of 2010.

COUNT 244

Nevada dated March 1, 2006, when Defendant TRAFFORD was not in Defendant’s presence

COUNT 245

Felony NRS 239.330

On or about March 1, 2006, Defendant TRAFFORD did, in the County of Clark, State of

On or about March 1, 2006, Defendant TRAFFORD, within Clark County, State of Nevada,

Official Records with the Office of the County Recorder of Clark County, Nevada dated March

COUNT 246

FELONY NRS 205.120

December of 2010.

COUNT 247

COUNT 248

Felony NRS 239.330

COUNT 249

December of 2010.

COUNT 250

COUNT 251

Felony NRS 239.330

COUNT 252

December of 2010.

COUNT 253

COUNT 254

On or about May 8, 2006, Defendant TRAFFORD, within Clark County, State of Nevada,

Official Records with the Office of the County Recorder of Clark County, Nevada dated May 8,

2006. Said document was forged in that it purported to be signed by Defendant TRAFFORD,

as the agent for the beneficiary of the property listed in said instrument, when in truth and in

fact Defendant TRAFFORD did not sign said instrument, as Defendant TRAFFORD well

knew. These actions were performed in a secretive manner in order that the false documents

COUNT 255

December of 2010.

COUNT 256

COUNT 257

Felony NRS 239.330

COUNT 258

December of 2010.

COUNT 259

COUNT 260

Felony NRS 239.330

COUNT 261

FELONY NRS 205.120

December of 2010.

COUNT 262

COUNT 263

Felony NRS 239.330

COUNT 264

FELONY NRS 205.120

December of 2010.

COUNT 265

COUNT 266

Felony NRS 239.330

COUNT 267

December of 2010.

COUNT 268

NOT IN PRESENCE NOTARY PUBLIC, a violation of NRS 240.155, a Gross Misdemeanor.

COUNT 269

Felony NRS 239.330

COUNT 270

December of 2010.

COUNT 271

COUNT 272

Felony NRS 239.330

COUNT 273

COUNT 274

COUNT 275

Felony NRS 239.330

COUNT 276

FELONY NRS 205.120

On or about October 2, 2006, DEFENDANT TRAFFORD, within the County of Clark,

the County Recorder of Clark County, Nevada dated October 2, 2006.

All of which constitutes the crime of FALSE CERTIFICATE TO CERTAIN INSTRUMENTS a

category D felony pursuant to NRS 205.120. These actions were performed in a secretive

COUNT 277

COUNT 278

Felony NRS 239.330

COUNT 279

FELONY NRS 205.120

December of 2010.

COUNT 280

COUNT 281

Felony NRS 239.330

COUNT 282

COUNT 283

COUNT 284

Felony NRS 239.330

COUNT 285

December of 2010.

COUNT 286

COUNT 287

Felony NRS 239.330

COUNT 288

December of 2010.

COUNT 289

COUNT 290

Felony NRS 239.330

COUNT 291

COUNT 292

COUNT 293

Felony NRS 239.330

COUNT 294

FELONY NRS 205.120

December of 2010.

COUNT 295

COUNT 296

Felony NRS 239.330

COUNT 297

December of 2010.

COUNT 298

COUNT 299

Felony NRS 239.330

COUNT 300

December of 2010.

COUNT 301

COUNT 302

Felony NRS 239.330

COUNT 303

December of 2010.

COUNT 304

COUNT 305

Felony NRS 239.330

COUNT 306

December of 2010.

COUNT 307

COUNT 308

Felony NRS 239.330

COUNT 309

FELONY NRS 205.120

December of 2010.

COUNT 310

COUNT 311

Felony NRS 239.330

COUNT 312

December of 2010.

COUNT 313

COUNT 314

Felony NRS 239.330

COUNT 315

December of 2010.

COUNT 316

COUNT 317

Felony NRS 239.330

COUNT 318

December of 2010.

COUNT 319

COUNT 320

Felony NRS 239.330

COUNT 321

December of 2010.

COUNT 322

COUNT 323

Felony NRS 239.330

On or about June 20, 2007, DEFENDANT TRAFFORD, within Clark County, State of

COUNT 324

December of 2010.

COUNT 325

COUNT 326

Felony NRS 239.330

COUNT 327

COUNT 328

when said person whose signature was being notarized was not in the notary’s presence, to

Nevada, planned, directed, or arranged to have JENNIFER LOWE, (hereinafter “LOWE”), a

Official Records filed in the Office of the County Recorder of Clark County, Nevada dated

February 18, 2005, when Defendant SHEPPARD was not in Defendant’s presence and

further never signed said document. These actions were performed in a secretive manner in

COUNT 329

Felony NRS 239.330

On or about February 18, 2005, Defendant SHEPPARD did, in the County of Clark,

COUNT 330

to JENNIFER LOWE, (hereinafter “LOWE”), a notary public appointed by the Nevada

County Recorder of Clark County, Nevada dated February 18, 2005. These actions were

December of 2010.

COUNT 331

February 23, 2005 when Defendant SHEPPARD was not in Defendant’s presence and further

never signed said document. These actions were performed in a secretive manner in order

that the false documents be given full legal effect and that this criminal activity not be

NOT IN PRESENCE NOTARY PUBLIC, a violation of NRS 240.155, a Gross Misdemeanor.

COUNT 332

Felony NRS 239.330

On or about February 23, 2005 Defendant SHEPPARD did, in the County of Clark,

On or about February 23, 2005 Defendant SHEPPARD, within Clark County, State of

COUNT 333

FELONY NRS 205.120

December of 2010.

COUNT 334

On or about March 2, 2005, Defendant SHEPPARD, within Clark County, State of

On or about March 2, 2005, Defendant SHEPPARD within Clark County, State of

March 2, 2005, when Defendant SHEPPARD was not in Defendant’s presence and further

never signed said document. . These actions were performed in a secretive manner in order

COUNT 335

Felony NRS 239.330

On or about March 2, 2005, Defendant SHEPPARD did, in the County of Clark, State

COUNT 336

On or about March 2, 2005, Defendant SHEPPARD, within the County of Clark, State

On or about March 2, 2005, Defendant SHEPPARD planned, directed, and arranged to

JENNIFER LOWE, (hereinafter “LOWE”), a notary public appointed by the Nevada Secretary

of State, and authorized to take proof or acknowledgment of an instrument, to forge and

willfully certify falsely that the execution of this instrument was acknowledged by her

County Recorder of Clark County, Nevada dated March 2, 2005. These actions were

December of 2010

COUNT 337

All of which constitutes the crime of NOTARIZATION OF SIGNATURE OF PERSON NOT IN

PRESENCE NOTARY PUBLIC, a violation of NRS 240.155, a gross misdemeanor.

COUNT 338

Felony NRS 239.330

COUNT 339

December of 2010.

COUNT 340

COUNT 341

Felony NRS 239.330

On or about March 7, 2005 Defendant SHEPPARD did, in the County of Clark, State of

COUNT 342

December of 2010.

COUNT 343

COUNT 344

Felony NRS 239.330

On or about March 25, 2005, Defendant SHEPPARD, within Clark County, State of Nevada,

Official Records with the Office of the County Recorder of Clark County, Nevada dated March

SHEPPARD, as the agent for the beneficiary of the property listed in said instrument, when in

truth and in fact Defendant SHEPPARD did not sign said instrument, as Defendant

SHEPPARD well knew. These actions were performed in a secretive manner in order that the

COUNT 345

December of 2010.

COUNT 346

On or about April 1, 2005, Defendant SHEPPARD, within Clark County, State of

On or about April 1, 2005, Defendant SHEPPARD within Clark County, State of

Official Records filed in the Office of the County Recorder of Clark County, Nevada dated April

1, 2005 when Defendant SHEPPARD was not in Defendant’s presence and further never

COUNT 347

On or about April 1, 2005, Defendant SHEPPARD did, in the County of Clark, State of

COUNT 348

On or about April 1, 2005 Defendant SHEPPARD, within the County of Clark, State of

On or about April 1, 2005, Defendant SHEPPARD planned, directed, and arranged to

County Recorder of Clark County, Nevada dated April 1, 2005. These actions were performed

in a secretive manner in order that the false documents be given full legal effect and that this

COUNT 349

COUNT 350

Felony NRS 239.330

COUNT 351

On or about April 6, 2005, Defendant SHEPPARD, within the County of Clark, State of

County Recorder of Clark County, Nevada dated April 6, 2005. These actions were

December of 2010.

COUNT 352

19, 2005, when Defendant SHEPPARD was not in Defendant’s presence and further never

COUNT 353

Felony NRS 239.330

COUNT 354

FELONY NRS 205.120

December of 2010.

COUNT 355

COUNT 356

Felony NRS 239.330

On or about April 21, 2005 Defendant SHEPPARD did, in the County of Clark, State of

COUNT 357

December of 2010.

COUNT 358

COUNT 359

Felony NRS 239.330

COUNT 360

On or about April 27, 2005 Defendant SHEPPARD, within the County of Clark, State of

December of 2010.

COUNT 361

NOT IN PRESENCE NOTARY PUBLIC, a violation of NRS 240.155, a gross misdemeanor

COUNT 362

Felony NRS 239.330

COUNT 363

December of 2010.

COUNT 364

On or about May 2, 2005, Defendant SHEPPARD, within Clark County, State of

On or about May 2, 2005, Defendant SHEPPARD within Clark County, State of

Official Records filed in the Office of the County Recorder of Clark County, Nevada dated May

COUNT 365

Felony NRS 239.330

On or about May 2, 2005 Defendant SHEPPARD did, in the County of Clark, State of

COUNT 366

On or about May 2, 2005, DEFENDANT SHEPPARD, within the County of Clark, State

On or about May 2, 2005, Defendant SHEPPARD planned, directed, and arranged to

County Recorder of Clark County, Nevada dated May 2, 2005. These actions were performed

COUNT 367

COUNT 368

On or about May 19, 2005, Defendant SHEPPARD did, in the County of Clark, State of

COUNT 369

On or about May 19, 2005, Defendant SHEPPARD, within the County of Clark, State of

County Recorder of Clark County, Nevada dated May 19, 2005. These actions were

December of 2010

COUNT 370

All of which constitutes the crime of NOTARIZATION OF SIGNATURE OF PERSON NOT

IN PRESENCE NOTARY PUBLIC, a violation of NRS 240.155, a gross misdemeanor.

COUNT 371

Felony NRS 239.330

On or about May 24, 2005 Defendant SHEPPARD did, in the County of Clark, State of

COUNT 372

December of 2010.

COUNT 373

COUNT 374

Felony NRS 239.330

DEFENDANT SHEPPARD well knew. These actions were performed in a secretive manner

COUNT 375

FELONY NRS 205.120

December of 2010.

COUNT 376

COUNT 377

Felony NRS 239.330

COUNT 378

December of 2010.

COUNT 379

June 2, 2005, when Defendant SHEPPARD was not in Defendant’s presence and further

COUNT 380

Felony NRS 239.330

On or about June 2, 2005 Defendant SHEPPARD did, in the County of Clark, State of

On or about June 2, 2005, Defendant SHEPPARD, within Clark County, State of Nevada,

Official Records with the Office of the County Recorder of Clark County, Nevada dated June

COUNT 381

On or about June 2, 2005, Defendant SHEPPARD, within the County of Clark, State of

County Recorder of Clark County, Nevada dated June 2, 2005. These actions were

December of 2010.

COUNT 382

COUNT 383

Felony NRS 239.330

On or about June 8, 2005, Defendant SHEPPARD did, in the County of Clark, State of

truth and in fact Defendant SHEPPARD did not sign said instrument, as Defendant well knew.

COUNT 384

On or about June 8, 2005 Defendant SHEPPARD, within the County of Clark, State of

December of 2010.

COUNT 385

COUNT 386

Felony NRS 239.330

COUNT 387

December of 2010

COUNT 388

June 13, 2005 when Defendant SHEPPARD was not in Defendant’s presence and further

COUNT 389

COUNT 390 FALSE CERTIFICATE TO CERTAIN INSTRUMENTS (AID &ABET)

FELONY NRS 205.120

December of 2010.

COUNT 391

COUNT 392

Felony NRS 239.330

COUNT 393

December of 2010.

COUNT 394

COUNT 395

Felony NRS 239.330

COUNT 396

FELONY NRS 205.120

December of 2010.

COUNT 397

On or about July 28, 2005, Defendant SHEPPARD, within Clark County, State of

On or about July 28, 2005, Defendant SHEPPARD within Clark County, State of

COUNT 398

Felony NRS 239.330

On or about July 28, 2005, Defendant SHEPPARD did, in the County of Clark, State of

COUNT 399

FELONY NRS 205.120

On or about July 28, 2005, Defendant SHEPPARD, within the County of Clark, State of

On or about July 28, 2005, Defendant SHEPPARD planned, directed, and arranged to

County Recorder of Clark County, Nevada dated July 28, 2005. These actions were

December of 2010.

COUNT 400

On or about August 2, 2005, Defendant SHEPPARD, within Clark County, State of

On or about August 2, 2005, Defendant SHEPPARD within Clark County, State of

August 2, 2005, when Defendant SHEPPARD was not in Defendant’s presence and further

COUNT 401

Felony NRS 239.330

On or about August 2, 2005, Defendant SHEPPARD did, in the County of Clark, State

COUNT 402

On or about August 2, 2005, Defendant SHEPPARD, within the County of Clark, State

On or about August 2, 2005, Defendant SHEPPARD planned, directed, and arranged to

December of 2010.

COUNT 403

COUNT 404

Felony NRS 239.330

COUNT 405

December of 2010.

COUNT 406

August 11, 2005 when Defendant SHEPPARD was not in Defendant’s presence and further

COUNT 407

Felony NRS 239.330

COUNT 408

On or about August 11, 2005, Defendant SHEPPARD planned, directed, and arranged

December of 2010.

COUNT 409

On or about September 14, 2005, Defendant SHEPPARD, within Clark County, State of

On or about September 14, 2005, Defendant SHEPPARD within Clark County, State of

September 14, 2005 when Defendant SHEPPARD was not in Defendant’s presence and

COUNT 410

On or about September 14, 2005, Defendant SHEPPARD did, in the County of Clark,

On or about September 14, 2005, Defendant SHEPPARD, within Clark County, State

COUNT 411

On or about September 14, 2005, Defendant SHEPPARD, within the County of Clark,

On or about September 14, 2005, Defendant SHEPPARD planned, directed, and

arranged to JENNIFER LOWE, (hereinafter “LOWE”), a notary public appointed by the Nevada

County Recorder of Clark County, Nevada dated September 14, 2005. These actions were

December of 2010.

COUNT 412

September 23, 2005, when Defendant SHEPPARD was not in Defendant’s presence and

COUNT 413

Felony NRS 239.330

COUNT 414

December of 2010.

COUNT 415

January 13, 2005, when Defendant SHEPPARD was not in Defendant’s presence and further

All of which constitutes the crime of NOTARIZATION OF SIGNATURE OF PERSON NOT IN

PRESENCE NOTARY PUBLIC, a violation of NRS 240.155, a gross misdemeanor.

COUNT 416

Felony NRS 239.330

COUNT 417

County Recorder of Clark County, Nevada dated January 13, 2005. These actions were

December of 2010.

COUNT 418

COUNT 419

Felony NRS 239.330

COUNT 420

On or about January 6, 2005, DEFENDANT SHEPPARD, within the County of Clark,

December of 2010.

COUNT 421

COUNT 422

Felony NRS 239.330

COUNT 423

On or about January 7, 2005, Defendant SHEPPARD, within the County of Clark, State

December of 2010.

COUNT 424

COUNT 425

Felony NRS 239.330

COUNT 426

December of 2010.

COUNT 427

COUNT428

Felony NRS 239.330

COUNT 429

December of 2010.

COUNT 430

COUNT 431

COUNT 432

December of 2010.

COUNT 433

COUNT 434

Felony NRS 239.330

COUNT 435

December of 2010.

COUNT 436

February 1, 2005, when Defendant SHEPPARD was not in Defendant’s presence and further

COUNT 437

Felony NRS 239.330

On or about February 1, 2005 Defendant SHEPPARD did, in the County of Clark, State

COUNT 438

FELONY NRS 205.120

On or about February 1, 2005, DEFENDANT SHEPPARD, within the County of Clark,

December of 2010.

COUNT 439

COUNT 440

Felony NRS 239.330

On or about February 10, 2005 Defendant SHEPPARD did, in the County of Clark,

COUNT 441

December of 2010.

COUNT 442

COUNT 443

Felony NRS 239.330

COUNT 444

December of 2010.

COUNT 445

COUNT 446

Felony NRS 239.330

COUNT 447

December of 2010.

COUNT 448

COUNT 449

Felony NRS 239.330

On or about March 8, 2005 Defendant SHEPPARD did, in the County of Clark, State of

COUNT 450

December of 2010.

COUNT 451

COUNT 452

On or about March 10, 2005 Defendant SHEPPARD did, in the County of Clark, State

COUNT 453

December of 2010.

COUNT 454

COUNT 455

Felony NRS 239.330

COUNT 456

December of 2010.

COUNT 457

COUNT 458

Felony NRS 239.330

On or about March 31, 2005, Defendant SHEPPARD did, in the County of Clark, State of

COUNT 459

FELONY NRS 205.120

December of 2010.

COUNT 460

COUNT 461

Felony NRS 239.330

On or about April 7, 2005 Defendant SHEPPARD did, in the County of Clark, State of

COUNT 462

December of 2010.

COUNT 463

COUNT 464

Felony NRS 239.330

COUNT 465

December of 2010.

COUNT 466

COUNT 467

Felony NRS 239.330

COUNT 468

County Recorder of Clark County, Nevada dated April 14, 2005. hese actions were performed

COUNT 469

18, 2005,when Defendant SHEPPARD was not in Defendant’s presence and further never

COUNT 470

Felony NRS 239.330

COUNT 471

December of 2010.

COUNT 472

COUNT 473

(AID &ABET)

Felony NRS 239.330

COUNT 474

December of 2010.

COUNT 475

COUNT 476

Felony NRS 239.330

COUNT 477

December of 2010.

COUNT 478

COUNT 479

Felony NRS 239.330

COUNT 480

December of 2010.

COUNT 481

COUNT 482

Felony NRS 239.330

COUNT 483

COUNT 484

COUNT 485

Felony NRS 239.330

COUNT 486

COUNT 487

COUNT 488

Felony NRS 239.330

COUNT 489

December of 2010.

COUNT 490

COUNT 491

Felony NRS 239.330

COUNT 492

December of 2010.

COUNT 493

COUNT 494

Felony NRS 239.330

COUNT 495

December of 2010.

COUNT 496

COUNT 497

Felony NRS 239.330

COUNT 498

December of 2010.

COUNT 499

COUNT 500

Felony NRS 239.330

OR RECORDING, a violation of NRS 239.330, a category C felony. /// /// ///

COUNT 501

FELONY NRS 205.120

County Recorder of Clark County, Nevada dated June 3, 2005. These actions were performed

COUNT 502

COUNT 503

Felony NRS 239.330

COUNT 504

December of 2010.

COUNT 505

COUNT 506

Felony NRS 239.330

COUNT 507

December of 2010.

COUNT 508

COUNT 509

Felony NRS 239.330

COUNT 510

December of 2010.

COUNT 511

COUNT 512

Felony NRS 239.330

COUNT 513

December of 2010.

COUNT 514

June 20, 2005,when Defendant SHEPPARD was not in Defendant’s presence and further

COUNT 515

COUNT 516

FELONY NRS 205.120

December of 2010.

COUNT 517

COUNT 518

Felony NRS 239.330

COUNT 519

December of 2010.

COUNT 520

COUNT 521

Felony NRS 239.330

COUNT 522

FELONY NRS 205.120

December of 2010.

COUNT 523

COUNT 524

Felony NRS 239.330

COUNT 525

December of 2010.

COUNT 526

COUNT 527

Felony NRS 239.330

DEFENDANT SHEPPARD, as the agent for the beneficiary of the property listed in said

instrument, when in truth and in fact DEFENDANT SHEPPARD did not sign said instrument,

as DEFENDANT SHEPPARD well knew. These actions were performed in a secretive

COUNT 528

December of 2010.

COUNT 529

COUNT 530

Felony NRS 239.330

COUNT 531

County Recorder of Clark County, Nevada dated July 5, 2005. These actions were performed

COUNT 532

COUNT 533

Felony NRS 239.330

COUNT 534

County Recorder of Clark County, Nevada dated July 6, 2005. These actions were performed

COUNT 535

COUNT 536

COUNT 537

December of 2010.

COUNT 538

COUNT 539

Felony NRS 239.330

dated July 12, 2005. Said document was forged in that it purported to be signed by

COUNT 540

December of 2010.

COUNT 541

COUNT 542

Felony NRS 239.330

COUNT 543

FELONY NRS 205.120

December of 2010.

COUNT 544

COUNT 545

Felony NRS 239.330

COUNT 546

December of 2010.

COUNT 547

COUNT 548

Felony NRS 239.330

COUNT 549

December of 2010.

COUNT 550

COUNT 551

Felony NRS 239.330

COUNT 552

December of 2010.

COUNT 553

COUNT 554

Felony NRS 239.330

COUNT 555

December of 2010.

COUNT 556

COUNT 557

Felony NRS 239.330

OR RECORDING, a violation of NRS 239.330, a category C felony. These actions were

December of 2010.

COUNT 558

FELONY NRS 205.120

December of 2010.

COUNT 559

COUNT 560

Felony NRS 239.330

COUNT 561

December of 2010.

COUNT 562

COUNT 563

Felony NRS 239.330

COUNT 564

December of 2010.

COUNT 565

COUNT 566

COUNT 567

December of 2010.

COUNT 568

September 29, 2005, when Defendant SHEPPARD was not in Defendant’s presence and

COUNT 569

Felony NRS 239.330

COUNT 570

December of 2010.

COUNT 571

On or about October 3, 2005, Defendant SHEPPARD within Clark County, State of

Nevada dated October 3, 2005, when Defendant SHEPPARD was not in Defendant’s

COUNT 572

Felony NRS 239.330

On or about October 3, 2005, Defendant SHEPPARD did, in the County of Clark, State

COUNT 573

On or about October 3, 2005, Defendant SHEPPARD, within the County of Clark, State

On or about October 3, 2005, Defendant SHEPPARD planned, directed, and arranged

to TRACY LAWRENCE, (hereinafter “LAWRENCE”), a notary public appointed by the Nevada

County Recorder of Clark County, Nevada dated October 3, 2005. These actions were

December of 2010.

COUNT 574

On or about November 4, 2005, Defendant SHEPPARD, within Clark County, State of

On or about November 4, 2005, Defendant SHEPPARD within Clark County, State of

Nevada dated November 4, 2005, when Defendant SHEPPARD was not in Defendant’s

COUNT 575

Felony NRS 239.330

On or about November 4, 2005, Defendant SHEPPARD did, in the County of Clark,

On or about November 4, 2005, Defendant SHEPPARD, within Clark County, State of

COUNT 576

On or about November 4, 2005, Defendant SHEPPARD, within the County of Clark,

On or about November 4, 2005, Defendant SHEPPARD planned, directed, and

arranged to TRACY LAWRENCE, (hereinafter “LAWRENCE”), a notary public appointed by the

December of 2010.

COUNT 577

COUNT 578

Felony NRS 239.330

COUNT 579

December of 2010.

COUNT 580

COUNT 581

Felony NRS 239.330

COUNT 582

December of 2010.

COUNT 583

COUNT 584

(AID & ABET) Felony NRS 239.330

COUNT 585

December of 2010.

COUNT 586

COUNT 587

Felony NRS 239.330

COUNT 588

On or about April 5, 2005, DEFENDANT SHEPPARD, within the County of Clark, State

December of 2010.

COUNT 589

COUNT 590

Felony NRS 239.330

COUNT 591

FELONY NRS 205.120

December of 2010.

COUNT 592

COUNT 593

Felony NRS 239.330

COUNT 594

On or about March 11, 2005, DEFENDANT SHEPPARD, within the County of Clark,

December of 2010.

COUNT 595

COUNT 596

Felony NRS 239.330

COUNT 597

December of 2010.

COUNT 598

COUNT 599

Felony NRS 239.330

COUNT 600

On or about March 21, 2005, DEFENDANT SHEPPARD, within the County of Clark,

December of 2010.

COUNT 601

COUNT 602

Felony NRS 239.330

COUNT 603

On or about June 9, 2005, DEFENDANT SHEPPARD, within the County of Clark,

December of 2010.

COUNT 604

COUNT 605

Felony NRS 239.330

COUNT 606

FALSE CERTIFICATE TO CERTAIN INSTRUMENTS (AID & ABET) Felony NRS 205.120

On or about March 16, 2007, Defendant TRAFFORD planned, directed, and

filed in the Office of the County Recorder of Clark County, Nevada dated March 16, 2007.

These actions were performed in a secretive manner in order that the false documents

All of which is contrary to the form, force and effect of the statutes in such cases made

and provided, and against the peace and dignity of the State of Nevada.

DATED this ______day of November, 2011 SUBMITTED BY: CATHERINE CORTEZ MASTO Attorney General By: ________________________________ JOHN P. KELLEHER Chief Deputy Attorney General Nevada Bar No. 005387 555 E. Washington Avenue, #3900 Las Vegas, Nevada 89101 702-486-3396 Attorneys for Plaintiff, State of Nevada

ENDORSEMENT: A True Bill By: _________________________________________ Foreperson, Clark County Grand Jury 11AGJ037AB

WITNESS LIST

1. Tracy Lawrence

4650 N. Rainbow, #1130 Las Vegas, NV 89108

2. Meghan Shaw

485 West 175 North Morgan, Utah 84050

3. Joseph Noel

3117 Oceanview Dr. Las Vegas, NV 89117

4. Bru Ethridge

Nevada Secretary of State Office Nevada State Capital Building 101 N. Carson St., Suite 3 Carson City, NV 89701

5. Eugene Mendiola

Clark County Recorder’s Office Clark County Government Center 500 S. Grand Central Pkwy., 2nd Flr. Las Vegas, NV 89155

6. Peter Horn 1151 Burton Dr., #230 Vacaville, CA 65687

7. Debra Watkins 3335 Hauck St., Apt 1016 Las Vegas, NV 89146

8. Romy Ashjian

1221 West Coast Hwy, #A-324 Newport Beach, CA 92663

9. Jennifer Bloecker

6500 Folkstone Ave., Unit 101A Las Vegas, NV 89108

10. Todd Grosz, Investigator Nevada Attorney General

Fraud unit 555 E. Washington Ave., #3900 Las Vegas, NV 89101 11. John Shaffer 8708 Foggy Bay Lane

Las Vegas, NV 89117

12. Tara D. Newberry, Esq. Managing Partner Connaghan|Newberry Law Firm 7854 W. Sahara Avenue Las Vegas, Nevada 89117

IND CATHERINE CORTEZ MASTO 2 JOHN P. KELLEHER 3 · The undersigned, CATHERINE CORTEZ MASTO,...

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