SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO FONTANA DISTRICT

THE PEOPLE OF THE STATE OF CALIFORNIA, ) COURT CASE NO Plaintiff vs. Judith Marie Oakes Defendant
) ) ) ) ) ) ) ) ) )

FELONY COMPLAINT

DA CASE NO 2013-00-0038460

The undersigned is informed and believes that: COUNT 1 On or about July 11, 2005 through August 28, 2006, in the above named judicial district, the crime of EMBEZZLEMENT BY PUBLIC OR PRIVATE OFFICER, in violation of PENAL CODE SECTION 504, a felony, was committed by Judith Marie Oakes, who on and between July 11th, 2005 and August 28, 2006, and while said defendant(s) was a Accountant for Rialto School District, did unlawfully, and fraudulently appropriate to a use and purpose not in the due and lawful execution of his/her trust, property which he/she had in his/her possession and under his/her control by virtue of his/her trust and did unlawfully secrete said property with a fraudulent intent to appropriate it to such a use and purpose contrary to Penal Code section 487(a), said property being of a value exceeding Four Hundred Dollars ($400).

***** COUNT 2 On or about September 11, 2006 through May 22, 2007, in the above named judicial district, the crime of EMBEZZLEMENT BY PUBLIC OR PRIVATE OFFICER, in violation of PENAL CODE SECTION 504, a felony, was committed by Judith Marie Oakes, who on and between September 11, 2006 and May 22, 2007, and while said defendant(s) was a Accountant for Rialto School District, did unlawfully, and fraudulently appropriate to a use and purpose not in the due and lawful
Page 1
Complaint DA CASE NO: 2013-00-0038460

execution of his/her trust, property which he/she had in his/her possession and under his/her control by virtue of his/her trust and did unlawfully secrete said property with a fraudulent intent to appropriate it to such a use and purpose contrary to Penal Code section 487(a), said property being of a value exceeding Four Hundred Dollars ($400).

***** COUNT 3 On or about October 8, 2007 through August 29, 2008, in the above named judicial district, the crime of EMBEZZLEMENT BY PUBLIC OR PRIVATE OFFICER, in violation of PENAL CODE SECTION 504, a felony, was committed by Judith Marie Oakes, who on and between October 8, 2007 and August 29, 2008, and while said defendant(s) was a Accountant for Rialto School District, did unlawfully, and fraudulently appropriate to a use and purpose not in the due and lawful execution of his/her trust, property which he/she had in his/her possession and under his/her control by virtue of his/her trust and did unlawfully secrete said property with a fraudulent intent to appropriate it to such a use and purpose contrary to Penal Code section 487(a), said property being of a value exceeding Four Hundred Dollars ($400).

***** COUNT 4 On or about September 2, 2008 through August 31, 2009, in the above named judicial district, the crime of EMBEZZLEMENT BY PUBLIC OR PRIVATE OFFICER, in violation of PENAL CODE SECTION 504, a felony, was committed by Judith Marie Oakes, who on and between September 2, 2008 and August 31, 2010, and while said defendant(s) was a Accountant for Rialto School District, did unlawfully, and fraudulently appropriate to a use and purpose not in the due and lawful execution of his/her trust, property which he/she had in his/her possession and under his/her control by virtue of his/her trust and did unlawfully secrete said property with a fraudulent intent to appropriate it to such a use and purpose contrary to Penal Code section 487(a), said property being of a value exceeding Four Hundred Dollars ($400).

Page 2
Complaint DA CASE NO: 2013-00-0038460

***** COUNT 5 On or about September 14, 2009 through August 31, 2010, in the above named judicial district, the crime of EMBEZZLEMENT BY PUBLIC OR PRIVATE OFFICER, in violation of PENAL CODE SECTION 504, a felony, was committed by Judith Marie Oakes, who on and between September 14, 2009 and August 31, 2010, and while said defendant(s) was a Accountant for Rialto School District, did unlawfully, and fraudulently appropriate to a use and purpose not in the due and lawful execution of his/her trust, property which he/she had in his/her possession and under his/her control by virtue of his/her trust and did unlawfully secrete said property with a fraudulent intent to appropriate it to such a use and purpose contrary to Penal Code section 487(a), said property being of a value exceeding Four Hundred Dollars ($400).

***** COUNT 6 On or about September 1, 2010 through August 29, 2011, in the above named judicial district, the crime of EMBEZZLEMENT BY PUBLIC OR PRIVATE OFFICER, in violation of PENAL CODE SECTION 504, a felony, was committed by Judith Marie Oakes, who on and between September 1, 2010 and August 29, 2011, and while said defendant(s) was a Accountant for Rialto School District, did unlawfully, and fraudulently appropriate to a use and purpose not in the due and lawful execution of his/her trust, property which he/she had in his/her possession and under his/her control by virtue of his/her trust and did unlawfully secrete said property with a fraudulent intent to appropriate it to such a use and purpose contrary to Penal Code section 487(a), said property being of a value exceeding Four Hundred Dollars ($400).

***** COUNT 7 On or about September 2, 2011 through August 29, 2012, in the above named judicial district, the crime of EMBEZZLEMENT BY PUBLIC OR PRIVATE OFFICER, in violation of PENAL CODE SECTION 504, a felony, was committed by Judith Marie Oakes, who on and between
Page 3
Complaint DA CASE NO: 2013-00-0038460

September 2, 2011 and August 29, 2012, and while said defendant(s) was a Accountant for Rialto School District, did unlawfully, and fraudulently appropriate to a use and purpose not in the due and lawful execution of his/her trust, property which he/she had in his/her possession and under his/her control by virtue of his/her trust and did unlawfully secrete said property with a fraudulent intent to appropriate it to such a use and purpose contrary to Penal Code section 487(a), said property being of a value exceeding Four Hundred Dollars ($400).

***** COUNT 8 On or about September 4, 2012 through August 6, 2013, in the above named judicial district, the crime of EMBEZZLEMENT BY PUBLIC OR PRIVATE OFFICER, in violation of PENAL CODE SECTION 504, a felony, was committed by Judith Marie Oakes, who on and between September 4, 2012 and August 6, 2013, and while said defendant(s) was a Accountant for Rialto School District, did unlawfully, and fraudulently appropriate to a use and purpose not in the due and lawful execution of his/her trust, property which he/she had in his/her possession and under his/her control by virtue of his/her trust and did unlawfully secrete said property with a fraudulent intent to appropriate it to such a use and purpose contrary to Penal Code section 487(a), said property being of a value exceeding Four Hundred Dollars ($400). ).

***** COUNT 9 On or about July 11, 2005 through August 28, 2006, in the above named judicial district, the crime of PUBLIC OFFICER CRIME, in violation of PENAL CODE SECTION 424, a felony, was committed by Judith Marie Oakes, who being a person described in Penal Code section 424 charged with the receipt, safekeeping, transfer, and distribution of public moneys, did in a manner not incidental and minimal knowingly keep a false account, and make a false entry and erasure in an account of and relating to the same.

Page 4
Complaint DA CASE NO: 2013-00-0038460

***** COUNT 10 On or about September 11, 2006 through May 22, 2007, in the above named judicial district, the crime of PUBLIC OFFICER CRIME, in violation of PENAL CODE SECTION 424, a felony, was committed by Judith Marie Oakes, who being a person described in Penal Code section 424 charged with the receipt, safekeeping, transfer, and distribution of public moneys, did in a manner not incidental and minimal knowingly keep a false account, and make a false entry and erasure in an account of and relating to the same.

***** COUNT 11 On or about October 8, 2007 through August 29, 2008, in the above named judicial district, the crime of PUBLIC OFFICER CRIME, in violation of PENAL CODE SECTION 424, a felony, was committed by Judith Marie Oakes, who being a person described in Penal Code section 424 charged with the receipt, safekeeping, transfer, and distribution of public moneys, did in a manner not incidental and minimal knowingly keep a false account, and make a false entry and erasure in an account of and relating to the same.

***** COUNT 12 On or about September 2, 2008 through August 31, 2009, in the above named judicial district, the crime of PUBLIC OFFICER CRIME, in violation of PENAL CODE SECTION 424, a felony, was committed by Judith Marie Oakes, who being a person described in Penal Code section 424 charged with the receipt, safekeeping, transfer, and distribution of public moneys, did in a manner not incidental and minimal knowingly keep a false account, and make a false entry and erasure in an account of and relating to the same.

*****
Page 5
Complaint DA CASE NO: 2013-00-0038460

COUNT 13 On or about September 14, 2009 through August 31, 2010, in the above named judicial district, the crime of PUBLIC OFFICER CRIME, in violation of PENAL CODE SECTION 424, a felony, was committed by Judith Marie Oakes, who being a person described in Penal Code section 424 charged with the receipt, safekeeping, transfer, and distribution of public moneys, did in a manner not incidental and minimal knowingly keep a false account, and make a false entry and erasure in an account of and relating to the same.

***** COUNT 14 On or about September 1, 2010 through August 29, 2011, in the above named judicial district, the crime of PUBLIC OFFICER CRIME, in violation of PENAL CODE SECTION 424, a felony, was committed by Judith Marie Oakes, who being a person described in Penal Code section 424 charged with the receipt, safekeeping, transfer, and distribution of public moneys, did in a manner not incidental and minimal knowingly keep a false account, and make a false entry and erasure in an account of and relating to the same. .

***** COUNT 15 On or about September 2, 2011 through August 29, 2012, in the above named judicial district, the crime of PUBLIC OFFICER CRIME, in violation of PENAL CODE SECTION 424, a felony, was committed by Judith Marie Oakes, who being a person described in Penal Code section 424 charged with the receipt, safekeeping, transfer, and distribution of public moneys, did in a manner not incidental and minimal knowingly keep a false account, and make a false entry and erasure in an account of and relating to the same.

***** COUNT 16
Page 6
Complaint DA CASE NO: 2013-00-0038460

On or about September 4, 2012 through August 6, 2013, in the above named judicial district, the crime of PUBLIC OFFICER CRIME, in violation of PENAL CODE SECTION 424, a felony, was committed by Judith Marie Oakes, who being a person described in Penal Code section 424 charged with the receipt, safekeeping, transfer, and distribution of public moneys, did in a manner not incidental and minimal knowingly keep a false account, and make a false entry and erasure in an account of and relating to the same.

It is further alleged, pursuant to Penal Code section 186.11(a)(2), that the offenses set forth in counts 1 thru 16 are related felonies, a material element of which is fraud and embezzlement, which involve a pattern of related felony conduct, and the pattern of related felony conduct involves the taking of more than five hundred thousand dollars ($500,000).

It is further alleged as to counts 1thru 16 that in the commission of the above offense(s) the said defendant(s) Judith Marie Oakes, with the intent to do so, took, damaged, and destroyed property of a value exceeding $1,300,000, within the meaning of Penal Code section 12022.6 (a)(3).

*****

NOTICE TO DEFENDANT AND DEFENDANTS ATTORNEY Pursuant to Penal Code Sections 1054.5.(b), the People are hereby informally requesting that defense counsel provide discovery to the People as required by Penal Code Section 1054.3. NOTICE TO ATTORNEY The materials accompanying this notice may include information about witnesses. If so, these materials are disclosed to you pursuant to Penal Code section 1054.2 which provides: "No attorney may disclose or permit to be disclosed to a defendant the address or telephone number of a victim or witness whose name is disclosed to the attorney pursuant to subdivision (a) of Section 1054.1 unless specifically permitted to do so by the court after a hearing and a showing of good cause."

Page 7
Complaint DA CASE NO: 2013-00-0038460

I DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT AND THAT THIS COMPLAINT CONSISTS OF 16 COUNT(S). Executed at Fontana, California, on October 8, 2013.

Richard A. Young Richard A. Young DECLARANT AND COMPLAINANT

Agency: Rialto Police Department

Defendant Judith Marie Oakes Birth Date 08/08/1964 Booking No. 1308340790

Prelim Est. 00:00

CII No. A23615774 NCIC

Page 8
Complaint DA CASE NO: 2013-00-0038460