8/4/2019 Grand jury indictment against Stephen Holgate

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ROD PACHECOAIL: Stephen Russell Holgate-W;alikr-District AttorneyCounty of Riverside

Riverside, California 9 2 50 13960 Orange Street, 1st FloorUPERIOR COURT OF CALIFORNIA

COUNTY OF RIVERSIDEFE

N O V 293 1 3 1 0elephone: (951) 955-5400Michael J. Cabral,Supervising Deputy District AttorneyS tate Bar N o : 1 2 6 6 6 0

S U P E R I O R C O U R T O F C A L I F O R N I AC O U N T Y O F R I V E R S ID E

T H E P E O P L E O F T H E S T A T E O FRiverside)N O. RIF 1 000S*V3C A L I F O R N I A , Plaintiff, I N D I C T M E N TV .S T E P H EN R U S S E L L H O L G A T E ,DefendantC O U N T 1

The Criminal Grand Jury of the County of Riverside by this Indictment hereby accusesSTEPHEN RU SSELL HOL GAT E of a violation of Penal Code section 18 2 , subdivision (a) ,subsection (I), a felony, in that on and between February 1 , 20 05 , and July 3 0, 2 008 , in the Countyof Riverside, State of California, he did wilfully and unlawfully conspire together and with anotherperson and persons whose identities are known and unknown to commit the crime of makingcampaign contributions in a false name, in violation of Government C ode sections 843 01 , and84302, misdemeanors, that pursuant to and for the purpose of carrying out the objects and purposesof the aforesaid conspiracy, the said defendants thereafter committed the following overt act andacts at and in the County of Riverside:

O V E R T A C T N O . 1On or about February 1 8, 2 00 8, Petra Tucker, at the request of Stephen Russell Holgate, issuedreimbursement checks to Petra Tucker, Matthew Wood and Byron Ellison for their contributionsto the Friends of John Benoit campaign;

ROD PACHECO

County of Riverside3960 Orange Street 1

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O V E R T A C T N O . 2On or about February 26, 2008, Mathew Wood made a contribution totaling Three Thousand SixHundred Dollars ($3 ,60 0.00 ) to the Friends of John Benoit campaign;

O V E R T A C T N O . 3On or about February 28 , 20 08 , Petra Tucker made a contribution totaling Three T housand SixHundred Dollars ($3,60 0.00 ) to the Friends of John Benoit campaign;

O V E R T A C T N O . 4On or about February 26 , 20 08 , Byron Ellison made a contribution totaling Three Thousand SixHundred Do llars ($3,60 0.00 ) to the Friends of John Benoit campaign;

O V E R T A C T N O . 5On or about M ay 1 4, 2 00 8, Stephen Russell Holgate made a contribution totaling Fifty T housandDollars to Conservative Leaders of America.

O V E R T A C T N O . 6On or about July 9, 2008, Peter Scheer made a , contribution totaling Five Thousand Dollars toConservative Leaders of America.

C O U N T 2For a further and separate cause of action, being a different offense from but connected in

its commission with the charge set forth in count 1 hereof, the Criminal Grand Jury of the Countyof Riverside by this Indictment hereby accuses STEPHEN RUSSELL HOLGATE of a violationof Government Code section 84301, a misdemeanor, in that on or about February 28, 2008, in theCounty of Riverside, State of California, that he did directly and indirectly contribute to theFriends of John Benoit Committee by a name other than the name by which the said defendantwas identified for legal purposes, to wit: in the name of Petra Tucker.

C O U N T 3For a further and separate cause of action, being a different offense from but connected in

its commission with the charges set forth in counts 1 and 2 hereof, the Criminal Grand Jury of theCounty of Riverside by this Indictment hereby accuses STEPHEN RUSSELL HOLGATE of aviolation of Government Code section 843 02 , a misdemeanor, in that on or about February 2 8,2008, in the County of Riverside, State of California, he did wilfully and unlawfully make acontribution on behalf of another, or while acting as an intermediary or agent of another withoutdisclosing to the recipient both his own full name, street address, occupation, name of hisemployer or principal place of business, and the full name, street address, occupation, name ofemployer or principal place of business of the other person.

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ROD PACHECO

County of Riverside3960 Orange Simi 2

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C O U N T 4For a further and separate cause of action, being a different offense from but connected in

its commission with the charges set forth in counts 1 through 3 hereof, the Criminal Grand Jury ofthe County of Riverside by this Indictment hereby accuses STEPHEN RUSSELL HOLGATE ofa violation of Government Code section 8 43 01 , a misdemeanor, in that on or about February 2 6 ,2008, in the County of Riverside, State of California, that he did directly and indirectly contributeto the Friends of John Benoit Committee by a name other than the name by which the saiddefendant was identified for legal purposes, to wit: in the name of Matthew Wood.

C O U N T 5For a further and separate cause of action, being a different offense from but connected in

its commission with the charges set forth in counts 1 through 4 hereof, the Criminal Grand Jury ofthe County of Riverside by this Indictment hereby accuses STEPHEN RUSSELL HOLGATE ofa violation of Government Code section 843 02 , a misdemeanor, in that on or about February 2 6 ,2008, in the County of Riverside, State of California, he did wilfully and unlawfully make acontribution on behalf of another, or while acting as an intermediary or agent of another withoutdisclosing to the recipient both his own full name, street address, occupation, name of hisemployer or principal place of business, and the full name, street address, occupation, name ofemployer or principal place of business of the other person.

C O U N T 6For a further and separate cause of action, being a different offense from but connected in

its commission with the charges set forth in count 1 through 5 hereof, the Criminal Grand Jury ofthe County of Riverside by this Indictment hereby accuses STEPHEN RUSSELL HOLGATE ofa violation of Government Code section 84 30 1 , a misdemeanor, in that on or about February 2 6 ,2008, in the County of Riverside, State of California, that he did directly and indirectly contributeto the Friends of John Benoit Committee by a name other than the name by which the saiddefendant was identified for legal purposes, to wit: in the name of Byron Ellison.

C O U N T 7For a further and separate cause of action, being a different offense from but connected in

its commission with the charges set forth in counts 1 through 6 hereof, the Criminal Grand Jury ofthe County of Riverside by this Indictment hereby accuses STEPHEN RUSSELL HOLGATE ofa violation of Government Code section 84 30 2 , a misdemeanor, in that on or about February 2 6 ,2008, in the County of Riverside, State of California, he did wilfully and unlawfully make acontribution on behalf of another, or while acting as an intermediary or agent of another withoutdisclosing to the recipient both his own full name, street address, occupation, name of hisemployer or principal place of business, and the full name, street address, occupation, name ofemployer or principal place of business of the other person.

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R O D P A C H E C ODistrict A

M icChief Deputy District Attorney

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C O U N T 8For a further and separate cause of action, being a different offense from but connected in

its commission with the charges set forth in counts I through 7 hereof, the Criminal Grand Jury ofthe County of Riverside by this Indictment hereby accuses STEPHEN RUSSELL HOLGATE, ofa violation of Government Code section 85 30 1 , a misdemeanor, in that on and between February1 2 , 20 08 and February 28 , 20 08 , in the County of Riverside, State of California, he did wilfullyand unlawfully make to any candidate for elective state office a contribution totaling more thanthree thousand six hundred dollars per election ($3,600).

C O U N T 9For a further and separate cause of action, being a different offense from but connected in

its commission with the charges set forth in counts 1 through 8 hereof, the Criminal Grand Jury ofthe County of Riverside by this Indictment hereby accuses STEPHEN RUSSELL HOLGATE ofa violation of Government Code section 843 01 , a misdemeanor, in that on or about July 9 , 20 08 ,in the County of Riverside, State of California, that he did directly and indirectly contribute to theConservative L eaders of America Comm ittee by a nam e other than the name by which the saidcontributor was identified for legal purposes.

C O U N T 1 0For a further and separate cause of action, being a different offense from but connected in

its commission with the charges set forth in counts 1 through 9 hereof, the Criminal Grand Jury ofthe County of Riverside by this Indictment hereby accuses STEPHEN RUSSELL HOLGATE ofa violation of Government Code section 8 43 02 , a misdemeanor, in that on or about July 9 , 20 08 ,in the County of Riverside, State of California, he did wilfully and unlawfully make acontribution on behalf of another, or while acting as an intermediary or agent of another withoutdisclosing to the recipient both his own full name, street address, occupation, name of hisemployer or principal place of business, and the full name, street address, occupation, name ofemployer or principal place of business of the other person.

Respectfully subm itted,

Dated: 1 , 1 )1 .MJC:dz

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ROD PACHECO

County or Riverside3960 Orange Streei

Riverside, California

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oreperson of the Criminal Grand Jury

rNames of witnesses examined by the Criminal Grand Jury on finding of the foregoingIndictment:John BenoitLynda C assadyPaul Anthony CourtneyAndrew DoKathleen DuranDavid Alfred GilHardKelly Ann LawlerFred NobleJames NygrenKim RobinsonPeter ScheerBob Sm ithPam SweatPetra TuckerRandy Patrick WastalN atalie B lanning-WeberBlaine Alan WomerMatthew Frederick Wo odChristopher Adolph W ysocki

A T R U E B I L L :

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ROD PACHECO

County of Riverside3960 Orange Street

Riverside, California

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