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TORI VERBER SALAZARDistrict AttorneyState Bar Membership No. 213636San Joaquin CountyBy: Stephen E. TaylorDeputy District AttorneyCourthouseStockton, CA 95202

Phone: (209) 468-2400Attorneys for Plaintiff

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SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN JOAQUINBRANCH

The People of the State of California, ) No. S ~ ~ 3 i 7~ 2 ~

Plaintiff,) PC 1275.1 ORDERv. )

MELVIN MONROE ADAMS DOB 11-08-1953 )AKA MARVIN ADAMS )AKA MICHAEL ALLEN )

Defendant(s). )

Good cause having been shown in the arrest warrant

declaration of Stockton Police Department Detective Mark

McLaughlin:

IT IS HEREBY ORDERED no bail be accepted from the above

entitled defendants until the source of the monies has been

examined by this court in compliance with the provisions of PC

X1275.1

Date : ~ ~ Z Z ~

123456

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Tori Verber SalazarDistrict Attorney

Stephen E. TaylorDeputy District AttorneySan Joaquin CountyCourthouseStockton, CA 95202Phone: (209) 468-2400

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SUPERIOR COURT OF CALIFORNIA

COUNTY OF SAN JOAQUIN JUDICIAL DISTRICT

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The People of the State of California,

Plaintiff,

V.

Melvin Monroe ADAMS DOB 11-08-1953AKA "Marvin Adams, Michael Allen"

Defendant s )

SPD CASE #14-24856

DECLARATIONIN SUPPORTOF ARRESTWARRANT

Your affiant hereby declares upon information and belief thefollowing:

That he is currently employed as a Detective for theStockton Police Department, and has been so employed, throughoutthis investigation; that pursuant to this employment, he has beenassigned to investigate allegations that the defendant didviolate Section s) 487 of the Penal Code;

That pursuant to this assignment, your affiant has contactedwitnesses, obtained their statements, and/or received verbal andwritten reports and statements prepared by others known by youraffiant to be law enforcement officers, and established thefollowing facts:

I, Detective Mark McLaughlin, began this investigation onJuly 6, 2014, while working The San Joaquin County Family Fair ina police security detail. I completed a preliminaryinvestigation which included contacting some of the victims,talking to the fairgrounds personnel, talking to Ralph White and

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49 "Michael Allen" on the phone. It should be noted that Michael50 Allen was later determined to be Melvin Monroe Adams, aka Marvin51 Adams. An ex-convict from California State Prison with a 9 page52 rap sheet showing a 2002, 5 year prison term for Grand Theft and53 felon in possession of a firearm out of Los Angeles.5455 On July 5 and 6th, 2014, I was assigned to work a police56 security detail at the San Joaquin Family Fair, located at the57 San Joaquin County Fair Grounds. During the course of working58 the event on July 5 and 6th, I was told by many of the vendors59 they were being double and triple charged by Blackstar Artist60 Management (Ralph White's Company) for the vendor spots. In61 addition, many of the event workers were openly saying they felt62 Michael Allen and Ralph White were working together with this63 event.6465 After I spoke with fair and police personnel, it appeared66 the San Joaquin Family Fair was an event at the San Joaquin67 County Fair grounds and put on by a third party entertainment68 company called "Next Level Concert Group." It was not authorized69 to be noted as the "San Joaquin County Fair" and did not have the70 authorization of the Fair Board to be known as the county fair.7172 On Sunday, July 6, 2014, at approximately 22:00 hours, while73 working the police security detail, I was assigned by Sergeant74 Walker to contact a group of vendors at the front gate. It was75 reported, the vendors were upset because they were not being paid76 for the past five (5) days of work.7778 I responded to the front gate of the fair grounds and met79 with several vendors and employees of Michael Allen (Next Level80 Concert Group).8182 There was a large group of people saying they were either83 employed by Michael Allen, signed contracts with Michael Allen84 (Next Level Concert Group/Backstar Artist Management), or had85 invoices billed to Michael Allen.8687 At the time of the preliminary investigation, there were88 reports of a large number of victims relating to this case. At89 that time, all the victims were not identified and the total loss90 was not known.9192 An unknown person who said he was one of the vendors for93 this event handed me their mobile phone and said Michael Allen94 wanted to talk to me. I spoke to the person on the phone who95 identified himself as Michael Allen. He told me it was a civil96 matter and the police did not need to be involved. I asked him

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97 if he owed the vendors money and he said yes, they would be paid98 at a later date.99

100 During this conversation with "Michael Allen" he101 continuously said it was a civil matter and the vendors would be102 paid. He said Ralph White had the authority to pay the vendors103 if they worked the event.104105 I asked Michael Allen to respond to the fairgrounds, but he106 refused saying he was not in Stockton. Michael Allen hung up the107 phone before I could get his personal information.108109 Another unknown vendor handed me a mobile phone and told me110 Ralph White was on the phone. I spoke to Ralph and immediately111 recognized his voice from prior contacts. Ralph said he assisted112 with the event because Michael Allen was ill and could not be113 there to handle it. Ralph said he collected the "Gate Money"114 with Kelly Olds and he had it with him. Kelly Olds works for the115 fair grounds. Ralph said he did not have the authority to pay116 the vendors and would not come to the fair grounds to help117 explain the situation to the vendors.118119 On Monday, July 7, 2014, I went to the Next Level Concert120 Group website and noted the web links either did not work, were121 noted as web links and were not actual links, or they went to web122 pages which were not related to the link. I also noted123 advertisements for "Official After Parties" for entertainers such124 as "CJ, Beyonce, and Justin Timberlake.125126 I spoke to Jessie Martin who is the owner of Pinnacle Web127 Design. According to Jessie, he was also hired by Michael Allen128 to manage employees and operations at the San Joaquin County129 Family Fair.130131 In his statement, Jessie said Michael Allen hired him in two132 capacities, as an employee of Michael Allen and Next Level133 Concert Group, and he contracted with Jessie's company for134 Website Design. Jessie's website company, Pinnacle Web Designs,135 was hired by Michael Allen to design and maintain three websites,136137 www.nextlevelconcertgroup.com138 www.bsamlive.com139 www.fair2014.com140141 Jessie also said, Michael provided the information and some142 of the graphics for the website and Jessie designed the format at143 Michael's direction. Michael has not paid him for the website144 services, which adds up to $2,000.00.

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145146 Jessie gave me the names "Chakeena Turner" and "Kendall147 Wright" who may have information regarding this case. Jessie148 said they worked with Michael Allen out of Los Angeles. Jessie149 also said Michael has been passing bad checks from Bank of150 America.151152 On July 7, 2014, I went to the Stockton, La Quinta Hotel and153 met with the hotel manager, Greg Hughes. La Quinta staff filed a154 report with the Stockton Police Department, because Michael Allen155 rented rooms for his employees and did not pay bill. Michael had156 previously attempted to use a credit card that declined. Greg157 and I reviewed the hotel security video system and located video158 showing "Michael Allen" at the front desk. Greg also reported159 Michael Allen had a signed contract with their night clerk to pay160 the bill. Michael Allen's employees stayed in 12 rooms from April161 4, 2015 through April 7, 2015. La Quinta currently has an162 outstanding balance from Michael Allen for $2,721.64. Michael163 Allen left without paying.164165 During a second interview with Ralph White, Ralph stated he166 has known this promoter for years and he is the person who167 brought him to Stockton. Ralph only knows him as "Marvin," and168 he does not know his last name.169170 Ralph stated, Marvin had to go to the hospital on the171 Thursday before the event. Because of this, Marvin asked Ralph172 to count everything and watch over the money.173174 Ralph said the Monday before the event, Ralph paid somebody175 $5,000 for the drums, and he paid $10,000 for the stage. Ralph176 was supposed to get the money back on Wednesday. Ralph said he177 was supposed to be paid back $20,000 but he only received $19,211178 and that money came from the gate money he collected the last179 night of the event.180181 Ralph said he had the authority to pay the police and182 fairgrounds, but he was not in the position of paying the others.183 The last night of the event, Marvin called Ralph and asked him to184 collect the money. Ralph met with Marvin at the Stockton Hilton185 Hotel in the parking lot, Sunday night and gave the money to him.186 Ralph did not count the money they collected; he just gave it to187 Marvin.188189 I checked with the Secretary of State for Nevada website and190 located recorded Limited Liability corporations for Blackstar191 Artist Management and Next Level Concert Group. Blackstar Artist192 Management was incorporated on April 28, 2014. Next Level

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193 Concert Group was incorporated on May 12, 2014.194195 On July 14, 2014, I completed a search warrant for the196 accounts at Bank of America, relating to Michael Allen, Kevin197 Williams, Blackstar Artists Management, and Next Level Concert198 Group. The Honorable Judge George Abdallah signed the warrant199 and I mailed it to the corporate offices of Bank of America. We200 received the bank records on or around July 27, 2014.201202 I spoke to Chakeena Turner (Keena) and Kendal Wright, both203 stating that Michael Allen hired them to work for him at204 Blackstar Artist Management and Next Level Concert Group. Keena205 and Kendal said Michael talked them into using their money for206 business operations and were promised by Michael they would be207 paid back in excess of the amounts they spent. Keena reported208 she was out $2,700.00 as a result of Michael not paying the money209 he owed her. Kendal reported Michael owes him approximately210 $2,000.00 as a result of Michael's failure to pay him.211212 On July 28, 2014, I spoke to Karen Sommer who was in Las213 Vegas. Karen Sommer is the owner of "Las Vegas Rentals 4 U," who214 provides furnished homes to corporate type organizations for215 temporary residents. Karen explained she rented a house to216 Michael Allen who had not paid the rent and she was in the217 process of kicking him out of the house. I received three218 pictures from Karen Sommer showing a vehicle used by an employee219 of Michael Allen. The employee said his name was Marvin.220221 The pictures showed a car with a "Carmax" paper plate so I222 called Carmax in Las Vegas. The staff at Carmax said the car was223 sold to "Marvin Adams" with a date of birth of 08-07-1986. I224 pulled a California DMV picture of this person and noted he225 appeared to be too young to be Michael Allen. I conducted a226 records check and located a Marvin Adams with a date of birth of227 11-08-1953. I pulled a picture of this Marvin Adams and I228 compared the pictures to a picture of Michael Allen. I noted the229 two pictures appeared to be the same person.230231 On August 11, 2014, I created a photo-lineup containing232 Marvin Adams in position number 4, along with five (5) other233 random photographs.234235 At 10:27 hours, I met with Kelly Olds at the San Joaquin236 County Fair Grounds. I advised Kelly per the Simmons237 admonishment and asked him to take his time and look at all the238 photographs prior to making any comments or statements.239240 I placed the lineup in front of Kelly and observed as he

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241 quickly looked at the photographs moving his eyes from side to242 side. Kelly then pointed to number 4 and said," this one, that's243 him." I confirmed he was talking about Michael Allen by asking244 him who number 4 was. Kelly said Michael Allen.245246 On August 20, 2014, at 11:30 hours, I went to the La Quinta247 Hotel in Stockton and met with Rebecca Garcia, a front desk clerk248 at La Quinta. I advised her per the Simmons admonishment and249 asked her to take her time and look at all the photographs prior250 to making any comments or statements. I showed her the photo-251 lineup I created on August 11, 2014, containing Marvin Adams in252 position number 4, along with five (5) other random photographs.253 Rebecca stated," That's him," and pointed to number 4 in the254 lineup.255256 A state records check of Marvin Adams showed an extensive257 criminal history with multiple convictions for Forgery, Grand258 Theft, and Insufficient Funds. Also one conviction for giving a259 false ID to a peace officer.260261 During this investigation, I contacted several people who262 reported they were victims of Michael Allen's false company.263 Below are brief summaries of specific details from each person264 who reported being a victim. NOTE: The suspect wi11 still be265 referred to as Michael Allen, but he was identified by his CA266 Driver's License alias, Marvin Adams. That California Driver's267 License then is listed on his California Rap Sheet as belonging268 to the former state prison inmate Melvin Monroe Adams. The DA is269 charging this case using the full name from the Rap sheet with270 his other names listed as AKAs.271272 Nazario ROJAS, Sonar Sound & Lighting - Count 1273 Nazario said he entered into a written contract agreement with274 Michael Allen to provide services and equipment for the San275 Joaquin County Family Fair. These services included setting up276 audio, staging, and taken down as well as controlling the277 equipment during the event.278279 The contract was for $12,675.00 and the agreement was, he would280 be paid in full on July 6, 2014 at the end of the event. He did281 not receive any payments on July 6, 2014. On July 7, 2014, the282 owner of the carnival gave Nazario a partial payment of $1,500.00283 at the direction of Michael Allen. Since that time, Nazario has284 not received any money towards the balance of $11,175.00.285286 Jorge VALDEZ, E1 Nuevo Imperio Enterprizes - Count 2287 Jorge said he drew up a contract for Michael Allen, but it never288 got signed. He said he and Michael Allen entered into a verbal

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289 agreement for $1,200.00 for the event's radio, video, and social290 media. During the event, Jorge told Michael Allen he was going291 to shut down the sites if he did not get paid. Michael paid him292293 $500, but never completed the agreement of $1,200.00, which294 brings the balance to $700.00.295296 Steven ROSEN, Steve's Fun Balloons - Count 2297 Steve is a self-employed entertainer for fairs and other events.298 Steve was told by a friend to contact Michael Allen regarding the299 San Joaquin County Family Fair. Steve emailed Michael Allen300 asking if he could perform at the event. Michael agreed to allow301 Steve to perform, but refused to sign a contract.302303 Michael and Steve came to an agreement between emails for304 providing Steve's services. The agreement was for Steve to305 stroll around the fair making balloon animals for free, for a306 minimum of four hours each day. They also agreed on a price of307 $400.00 each day, with a total of $2,000.00. In addition,308 Michael Allen agreed to pay for Steve's hotel.309310 Steve met Henry Mason, the carnival owner, at the fair grounds311 and was paid $1.000.00 of the $2,000.00 owed. There is still an312 outstanding balance of $1,455.00, including hotel cost.313314 Steve BLOOM, Hip Entertainment - Count 3315 Steve entered into a contract with Michael Allen to get local316 country bands at the San Joaquin County Family Fair. Michael317 Allen then later expanded his request by asking for better known318 entertainers such as "Jack Ingram."319320 Steve said his contact with Michael Allen was done over the phone321 and they completed a contract via email. Steve became concerned322 when Michael paid with a business check instead of a cashier's323 check which is the normal process. Michael also promised to324 "wire" the money which never happened. Steve said he has not325 received any payments other than the checks which bounced on a326 closed account. Michael Allen and Next Level Concert Group owe327 Steve Bloom $21,700.00 for the completed services.328329 Holly FORD, Ford Farms - Count 4330 Holly Ford is the owner of Ford Farms Petting Zoo. Holly Ford331 and Michael Allen from Next Level Concert Group entered into a332 contract to provide a petting zoo at the San Joaquin County333 Family Fun Fair.334335 The contract was for services involving the petting zoo and was336 for $4,000.00. Holly requested a 50o deposit, but Michael

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337 refused and said she would be paid at the end of the event. As338 of this date, Holly has not received any payment for her339 services. Holly had her petting zoo there for the entire five340 days of the event.341342 Brent HARRIS, Tony Toni Tone, West Wind Artists Inc - Count 5343 Brent Harris works for KBM West Wind Artists Inc., and represents344 singers Tony Toni Tone. Brent entered into a contract with345 Michael Allen for $15,000 plus hotel expenses. He has received a346 deposit of $7,500, cash for $2,500, and the hotel was paid.347 Michael Allen still has an outstanding balance of $5, 000.00.348 The contract was to be paid in full at the time of the349 performance. West Wind Artists Inc has not received any money350 towards the balance of $5,000.00, and Brent completed the terms351 of his contract.352353 Drew PALMER, Palmer Advertising - Count 6354 Drew is the owner of Palmer Advertising. He said he entered into355 a written contract with Michael Allen for advertising cost356 associated with radio, billboards, and social media such as357 Facebook and Twitter. Drew is accountable for payments as a part358 of his contract with Michael Allen to CBS Outdoor and Cumulus359 Radio.360361 According to the agreement between Drew and Michael Allen,362 payments were to be made at the "placement of the media," which363 means at the time the media was ordered. All the payments were364 to me made prior to the event. Drew has not received any365 payments toward the outstanding balance. Drew completed all the366 terms of their contract.367368 On June 20, 2014, Michael Allen gave Drew a check for $10,000.00369 to go towards media, but the check bounced. Drew stated there is370 an outstanding balance of $38,650.00 for his services.371372 London KIRKHAM, The Berkeley Group LLC, NV Jets - Count 7373 London is the owner of a jet company which provided private jet374 services to clients. On June 20, 2014, in the late evening,375 Michael Allen called her requesting her services for the early376 morning of June 21st. London sent Michael a written contract377 which included completing the information of a credit card378 payment. Michael Allen returned the contract with the required379 information. London attempted to run the credit card, but her380 authorization system was down. She informed Michael Allen who381 told her his office was located in the same building as her382 office and that he would pay her by check on Monday June 23.383384 Because Michael appeared to be a local business owner working in

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385 the same building as London, she agreed to the payment method and386 provided Michael Allen the service of flying him to Stockton387 California on June 21, 2104 and the return flight the same day.388 Upon Michael Allen's arrival in Las Vegas, London met him at the389 plane and introduced herself. Michael Allen reaffirmed the390 payment would be made on Monday the 23.391392 On Monday, June 23, 2014, London went to their building393 receptionist and asked for Michael Allen. London was told by the394 receptionist that Michael Allen and his company had been evicted.395 The bill for the round trip flight from Las Vegas to Stockton was396 $12,160.05 including waiting time while Michael was in Stockton397 during the day.398399 Dave DUNNING, Legends Theatrical - Count 8

400 Dave said on or around June 17, 2014, Michael Allen of Next Level401 Concert Group contacted him to retain services for the San402 Joaquin County Family Fair. The initial agreement was for403 staging, lighting, sound, rigging, and labor. Michael Allen404 later added "backline" service which includes instruments. The405 total for the listed services came to $69.200.00. The original406 invoice was completed on June 25, 2014.407408 On June 30, 2014, while Dave's crew was in Stockton setting up,409 Dave demanded a deposit because no payments had been made. At410 that time, Ralph White delivered a cashier's check to Dave for411 $10,000.00. This brought the balance to $59,200.00.412413 On July 2, 2014, Michael Allen delivered two checks to Dave414 totaling $41,000.00 while they were at the fairgrounds, bringing415 the balance down to $18,200.00. On July 4th, Dave demanded the416 balance due of $18,200.00. At the request of Ralph White, Dave417 sent his employee to Henry Mason (Carnival owner) to get the418 balance of the money owed. Henry paid the $18,200.00, which419 should have brought the balance to zero for the completed420 services he provided.421422 On July 7, 2014, Dave was received bank notice that the two423 checks had bounced and were written on an account that never had424 any money in it. The outstanding balance for the completed425 services is $41,000.00.426427 Chakeena Tuner - Count 9

428 Statement is listed in the initial portion of this document for429 chronological order and the steps of the investigation. Line 205430 to 213431432 Kendal Wright - Count 10

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433434435436437438439440441442443444445446447448449450451452453454455456457458459460461462463464465466467468469470471472473474475476477478479480

Statement is listed in the initial portion of this document forchronological order and the steps of the investigation. Line 205to 213

Jessie Martin - Count 11Statement is listed in the initial portion of this document forchronological order and the steps of the investigation. Line 126to 152

Jeff MARTIN, Comedy Entertainer - Count 12

Jeff and Pam Martin sent Michael Allen a contract on June 4, 2014

for Jeff Martin's comedy entertainment services. They receivedthe contract back from Michael Allen on June 10, 2014 with whatappeared to be Michael Allen's signature. The agreement in thecontract was for $3,000.00 for comedy entertainment services,plus hotel accommodations. In the agreement, payment for theservices was to be made no later than July 6th, 2014, beforeJeff's last show.

Although Jeff met the terms of their agreement, no payments weremade before o~ during the event, but Jeff received $1,000.00 fromthe carnival owner Henry Mason on July 7, 2014. The outstandingbalance due from Michael Allen is $2,408.61 which includes thecost of hotel accommodations.

Christopher BENHAM, The Medics Plus Inc - Count 13

Chris is the vice President of "The Medics Plus Inc" and was

involved in the event preparation, services during the event, andthe billing after. Chris said Michael Allen called him a fewdays before May 20, 2014 asking for their services for the SanJoaquin County Family Fair. Michael signed a contract for (4)EMTs and (1) Nurse at all times during the event. This servicewas provided to the Next Level Concert Group and was invoiced asrequired in the signed contract. The contract was for a total of$3,000.00 for all services, equipment, and supplies.

Payment was required per the contract to be made no later than 10days after the end of the event. The Medics Plus Inc. has notreceived any payments for their services during the event.

Robert CASTILLO, BMX Freestyle Team - Count 14

Robert is the owner of the "BMX Freestyle Team" which provided

services to the San Joaquin County Family Fair. Robert was

contacted by Michael Allen by telephone and Robert sent him acontract. Michael returned the signed contract agreeing to thefollowing details.

The BMX Freestyle Team would perform every day at the event.

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481 They would perform three shows each day on the weekday events and482 four shows each day on the weekend events. The agreement was483 between Michael Allen and Robert Castillo from The BMX Freestyle484 for $8.375.00 for the services, payable by check on the last day485 of the event.486487 Robert has not received any payments as a result of providing the488 services to the event and he provided all the required shows489 during the event.490491 Tina GASSERT, Master Hypnotist - Count 15492 Tina is a self-employed entertainer and provides entertainment at493 fairs and other events. She originally received a call from an494 unknown male asking if she would be interested in performing at495 the San Joaquin County Family Fair. After she agreed, Michael496 Allen called her and she sent him a contract. Michael Returned497 the signed contract dated June 8, 2014.498499 The contractual agreement was Michael Allen would pay Tina500 $5,000.00 for two shows every night of the event. Payment was to501 be made by check on the last day of the event. No payment has502 been made since the event.503504 Tina performed all the required shows except the last show on the505 last night of the event. She was bumped off her stage by Jesse506 Martin so a Spanish Band could use her stage. Tina was never507 given the opportunity to make up the show.508509 Francisco SERRANO, Serrano Printing Association - Count 16510 Francisco said around June 3, 2014, Michael Allen called him511 asking for his services. They provided services producing512 shirts, posters, fliers, and advertisements. They are currently513 owed $4,891.92 and have not received any payments. Francisco514 entered into the business arrangement by verbally agreeing to515 provide the services and submit invoices as they provide the516 service. Francisco said his agreement with Michael Allen was517 that he pays each invoice at the time he receives it. Francisco518 began calling Michael Allen after the first invoice, but Michael519 just kept saying the check was in the mail.520521 Terry ROBINSON, Dr. Solar - Count 17522 Terry is a self-employed entertainer for fairs and other events.523 He was contacted about participating in the San Joaquin County524 Family Fair by an unknown person claiming to work for Michael525 Allen. After the initial conversation, Terry called Michael Allen526 and asked him if he was still interested in using Terry for the527 event.528

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529 Michael agreed and Terry sent him a contract. The contract was530 for three, half hour shows, each day with three to four hours of531 strolling entertainment. Terry asked for a deposit, but was told532 by Michael Allen the time frame was too short to get the deposit533 to him. According to the contract, a $3.500.00 payment was due534 upon completion of the event or before. Terry completed all his535 shows.536537 At the end of the event, Terry did not receive any payment for538 his contracted services. On July 7, 2014, Michael told Terry to539 meet the carnival owner at the fair grounds and he would pay him.540 Terry met Henry Mason, the carnival owner, at the fair grounds541 and was paid $1.500.00 of the $3,500.00 owed. There is still an542 outstanding balance of $2,000.00543

544 La Quinta Hotel - Count 18

545 Statement is listed in the initial portion of this document for546 chronological order and the steps of the investigation. Line 154547 to 163

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549 Victim List with reported loss550 Nazario ROJAS, Sonar Sound & Lighting $11,175.00551 Jorge VALDEZ, El Nuevo Imperio Enterprizes $700.00552 Steven ROSEN, Steve's Fun Balloons $1,455.00553 Steve BLOOM, Hip Entertainment $21,700.00554 Holly FORD, Ford Farms $4,000.00555 Brent HARRIS,Tony Toni Tone,West Wind Artists Inc $5,000.00556 Drew PALMER, Palmer Advertising $38,650.00557 London KIRKHAM, The Berkeley Group LLC, NV Jets $12,160.05558 Dave DUNNING, Legends Theatrical $41,000.00559 Chakeena TURNER $2,700.00560 Kendall WRIGHT $2,000.00561 Jessie MARTIN, Pinnicle Web Design $2,000.00562 Jeff MARTIN, Comedy Entertainer $2,408.61563 Christopher BENHAM, The Medics Plus Inc $3,000.00564 Robert CASTILLO, BMX Freestyle Team $8.375.00565 Tina GASSERT, Master Hypnotist $5.000.00566 Francisco SERRANO, Serrano Printing Association $4,891.92567 Terry ROBINSON, Dr. Solar $2,000.00568 La Quinta Hotel $2,721.64.569570 TOTAL AMOUNT OF UNPAID CONTRACTS $170.937.22571572 Based on this investigation, your affiant believes Marvin573 Adams used the name of Michael Allen to start two entertainment574 companies. Blackstar Artist Management was incorporated on April575 28, 2014. Next Level Concert Group was incorporated on May 12,576 2014. Marvin Adams created the Limited Liability Corporations for

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577 the companies as well as websites appearing to be valid and578 professional. Marvin signed a contract with Jessie Martin on May579 15, 2015 for the website designs. In addition, Marvin Adams580 either opened or caused to be opened bank accounts with Chase581 Bank and Bank of America under these companies and assumed name.582583 Marvin contracted with entertainers, vendors, and the venue584 to put on the "San Joaquin County Family Fair." Marvin Adams585 conducted this business with an assumed name, having no586 substantial capital in the bank, and not paying the deposits587 normally required to retain such entertainment and vendors. In588 addition, according to Ralph White, Marvin Adams collected a589 large portion of the event gate fees through Ralph or other590 workers.591592 Your affiant requests a warrant be issued with the following593 charge(s):594595 Eighteen Counts of PC 487a Grand Theft as Felonies, for the596 takings from the above victims. Here we have classic Theft by597 False Pretense. Your affiant cites CALCRIM Instruction 1804.598 It does appear from all the witness statements and events599 discussed above that defendant Marvin Adams came to Stockton600 with a scheme to obtain labor and property without paying601 including the jet he flew in and out on, the hotel rooms he602 stayed in with his entourage and all the services from the603 various local venders and temporary employees who weren't paid604 either. While some small payments were made as demanded up605 front these victims were all told they would be paid generally606 with the gate receipts by the end of the Fair. Marvin Adams607 appears to have flown by night on the unpaid jet with the Gate608 receipts (described by Ralph Lee White as being a boatload of609 money which he didn't count. Your affiant as of today has no610 information of any of these victims being paid a thing since611 Marvin left town. Based on these facts I have reason to612 believe and I do believe that Marvin Adams entered into all613 these contracts with the various victims with no intention to614 pay the contract price. The dollar amounts are so large the615 District Attorney has added amount enhancements to the crimes616 for excessive takings of over $65,000 for additional time in617 prison and $100,000 for Aggravated White Collar Crime618 sentencing enhancement (No realignment, a consecutive619 additional prison term as per PC 186.11(1), etc).620621 Based on the defendant's history of fraudulent business dealing622 both locally and across state lines, I believe he is a flight623 risk. I believe the defendant has quick access to additional624 large sources of illicit money, as well as the money from this

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625 scam.626627 Standard bail for theft with amount enhancements is generally the628 amount of the loss. The loss charged is $170,000. As far as is629 known defendant lives somewhere in Nevada and frequents Southern630 California. He has no ties to this community. Based on all the631 above, I therefore pray the defendant's bail be enhanced to632 $250,000 cash only and he be required to show the non-felonious633 source of any such bail pursuant to Penal Code section 1275. I634 also ask the court to order he not be court capped as he is635 facing a substantial prison term well in excess of ten years in636 State Prison because of the number of counts and the Aggravated637 White Collar Crime enhancement.638639640 I declare under penalty of perjury that the foregoing is true and641 correct to the best of knowledge and belief.642643644 Dated this ~2--~- day of ~~, {~ 20156456 4 6 ~.,6476 4 8 ~+ 't ', -~~'6 4 9 1~ l , _~ _ /~~~650 Detee~. e Mark McLaughlin, Stockton Police Department

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SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN JOAQUIN

The People of the State of California, )

Plaintiff, )

v. ~

MELVIN MONROE ADAMS

Defendant(s). ~

Ct. No.DA No. CR-2015-4091686CR No. SPD 14-24856FELONYARREST WARRANT

THE PEOPLE OF THE STATE OF CALIFORNIA,

TO ANY PEACE OFFICER IN THIS STATE:

Complaint on oath having this day been made before me that the crimes) of:

CT. 1 PC 487 GRAND THEFT OF PERSONAL PROPERTY OVER $950.00, A FELONYCT. 2 PC 487 GRAND THEFT OF PERSONAL PROPERTY OVER $950.00, A FELONYCT. 3 PC 487 GRAND THEFT OF PERSONAL PROPERTY OVER $950.00, A FELONYCT. 4 PC 487 GRAND THEFT OF PERSONAL PROPERTY OVER $950.00, A FELONYCT. 5 PC 487 GRAND THEFT OF PERSONAL PROPERTY OVER $950.00, A FELONYCT. 6 PC 487 GRAND THEFT OF PERSONAL PROPERTY OVER $950.00, A FELONYCT. 7 PC 487 GRAND THEFT OF PERSONAL PROPERTY OVER $950.00, A FELONYCT. 8 PC 487 GRAND THEFT OF PERSONAL PROPERTY OVER $950.00, A FELONYCT. 9 PC 487 GRAND THEFT OF PERSONAL PROPERTY OVER $950.00, A FELONYCT. 10 PC 487 GRAND THEFT OF PERSONAL PROPERTY OVER $950.00, A FELONYCT. 11 PC 487 GRAND THEFT OF PERSONAL PROPERTY OVER $950.00, A FELONYCT. 12 PC 487 GRAND THEFT OF PERSONAL PROPERTY OVER $950.00, A FELONYCT. 13 PC 487 GRAND THEFT OF PERSONAL PROPERTY OVER $950.00, A FELONYCT. 14 PC 487 GRAND THEFT OF PERSONAL PROPERTY OVER $950.00, A FELONYCT. 15 PC 487 GRAND THEFT OF PERSONAL PROPERTY OVER $950.00, A FELONYCT. 16 PC 487 GRAND THEFT OF PERSONAL PROPERTY OVER $950.00, A FELONYCT. 17 PC 487 GRAND THEFT OF PERSONAL PROPERTY OVER $950.00, A FELONYCT. 18 PC 487 GRAND THEFT OF PERSONAL PROPERTY OVER $950.00, A FELONYPC 186.11(A)(1) AGGRAVATED WHITE COLLAR CRIME ENHANCEMENTPC 12022.6(A)(1) TAKE, DAMAGE,DESTROY PROPERTY OVER $65,000.00

has been committed and accusing defendant thereof;

YOU ARE THEREFORE COMMANDED forthwith to arrest the above-named defendantand bring him ar her before the San Joaquin County Superior Court, 222 E. Weber Avenue, Stockton,CA, or in case of my absence or inability to act, before the nearest or most accessible magistrate inSan Joaquin County.

Defendant is to ($ ~l Bail Cash Only if checked here.be admitted to bail ($ ~~ Penalty Assessmentin the sum of ------------------- ($ ~~~ )Total Bail

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Defendant ( )MAY or ( )MAY NOT be released on signed promise to appear (§§ 818/853.6 PC).If for a felony, this warrant may be served at night. _

Witness my hand and the seal of said Court, this ~ay of ~~ ~~ , 20 ~~

~D ̀-~ ~nSeal

JUDGE OF THE SUPERIOR COURT

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Race: Black3 Height: 5' 11"4 Hair: Black

DOB: 11/08/19535 DL #: N3525697

6 Residence: UNKNOWN

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DEFENDANT'S DESCRIPTION

Sex: MaleWeight: 220Eyes: Brown

DL State: CA

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TORI VERBER SALAZAR

District Attorney

San Joaquin County

State Bar No. 213636By: STEPHEN E. TAYLOR

Deputy District Attorney

222 E. Weber AvenueStockton, CA 95202

209.468.2400; Fax 209.465.0371

Attorneys for Plaintiff

;r.L f ,~F` FIl..~'C~1u;r-~,r~_ :t~_:

w'. a4

SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN JOAQUIN

Stockton Branch

The People of the State of California, No. ~ ~ ~ ~I 7~2

SPD CASE

Plaintiff, DA Case: CR-2015-4091686

v.COMPLAINT

MELVIN MONROE ADAMS DOB 11-08-1953

AKA MARVIN ADAMS

AKA MICHAEL ALLEN

Defendant (s) .

I, the undersigned, say, on information and belief, that in the

County of SAN JOAQUIN, State of California:

COUNT 1: GRAND THEFT OF PERSONAL PROPERTY OVER $950 PC.487(a)<F5FEL

On or about May 15, 2014 - July 6, 2014, in the County of San

Joaquin, California, MELVIN MONROE ADAMS, did commit the crime of

GRAND THEFT OF PERSONAL PROPERTY OVER $950.00 in violation of

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Section 487 (a) of the Penal Code, a FELONY, who at the time and

place last aforesaid, did willfully and unlawfully take money,

labor or personal property of another of a value exceeding nine

hundred fifty dollars ($950.00), to-wit: NAZARIO ROJAS DBA SONAR

SOUND AND LIGHTING; $11, 175.00 FOR SETTING UP AUDIO, STAGING AND

CONTROLLING ALL EQUIPMENT.

For a further and separate cause of complaint, being a different

statement of the same offense as the charge s) above, complainant

Further complains and says:


:Jn or about May 15, 2014 - July 6, 2014, in the County of San

~~aquin, California, MELVIN MONROE ADAMS, did commit the crime of

=.WRAND THEFT OF PERSONAL PROPERTY OVER $950.00 , in violation of

~~ction 487 (a) of the Penal Code, a FELONY, who at the time and


labor and personal property of another of a value exceeding nine

hundred fifty dollars ($950.00), to-wit: JORGE VALDEZ DBA EL NUEVO

IMPERIO ENTERPRISES AND STEVE ROSEN DBA STEVE'S FUN BALLOONS,

$2,155.00 FOR GOODS AND SERVICES RENDERED.



further complains and says:

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hundred fifty dollars ($950.00), to-wit: STEVE BLOOM DBA HIP

ENTERTAINMENT; $21,700.00 FOR ENTERTAIc"~iENT SERVICES.

For a further and separate cause of cor~~~laint, being a different

statement of the same offense as the charge (s) above, complainant


COUNT 4: GRAND THEFT OF PERSONAL PROPERLY OVER $950 PC.487(a)<F5FEL

On or about May 15, 2014 - July 6, 201ti, in the County of San

Joaquin, California, MELVIN MONROE ADA~•:S, did commit the crime of





hundred fifty dollars ($950.00), to-wit: HOLLY FORD, DBA FORD

FARMS, $4,000.00 FOR PETTING Z00 SERVICES.




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Joaquin, California, ME~LVIN MONROE ADAMS, did commit the crime of





hundred fifty dollars ($950.00), to-wit: BRENT HARRIS, DBA TONY

TOI~?I TONE, WEST WIND ARTISTS, INC., $5,000.00 FOR ENTERTAINMENT

SEF:~IICES .

Fora further and separate cause of complaint, being a different

st~-:tement of the same offense as the charge s) above, complainant

fuY~~er complains and says:


On .:,r about May 15, 2014 - July 6, 2014, in the County of San






hundred fifty dollars ($950.00), to-wit: DREW PALMER, DBA PALMER

ADVERTISING, $38,650.00 FOR ADVERTISING SERVICES.


statement of the same offense as the charges) above, complainant


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GRAND THEFT OF PERSONAL PROPERTY OVER $950.00 , in violation of




hundred fifty dollars ($950.00), to-wit: LONDON KIRKHAM, DBA THE

BERKELEY GROUP, LLC., NV JETS, FOR $12,160.05 FOR PRIVATE JET

SERVICE.

For a further and separate cause of compl<:~.t1t, being a different

statement of the same offense as the char~(s) above, complainant



On or about May 15, 2014 - July 6, 2014, i:~ the County of San






hundred fifty dollars ($950.00), to-wit: DAVE DUNNING, DBA LEGENDS

THEATRICAL, $41,000.00 FOR STAGING, LIGHTING, RIGGING AND

INSTRUMENT RENTAL SERVICES.

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1 For a further and separate cause of complaint, being a different

2 statement of the same offense as the charge s) above, complainant

3 further complains and says:

4 COUNT 9: GRAND THEFT OF PERSONAL PROPERTY OVER $950 PC.487(a)<F5FEL

5On or about May 15, 2014 - July 6, 2014, in the County of San

6Joaquin, California, MELVIN MONROE ADAMS, did commit the crime of

7GRAND THEFT OF PERSONAL PROPERTY OVER $950.00 in violation of

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Section 487(a) of the Penal Code, a FELONY, who at the time and9

place last aforesaid, did willfully and unlawfully take money,10

11 labor and personal property of another of a value exceeding nine

12 hundr~ci fifty dollars ($950.00), to-wit: CHAKEENA TURNER, AN

13 INDI~J~!'DUAL, $2, 700.00 FOR CASH ADVANCES.

14 For G aurther and separate cause of complaint, being a different

15 statement of the same offense as the charge s) above, complainant

16 further complains and says:

l~ COUNT 10: GRAND THEFT OF PERSONAL PROPERTY OVER $950 PC.487(a)<F5EEL

18 On or about May 15, 2014 - July 6, 2014, in the County of San

19Joaquin, California, MELVIN MONROE ADAMS, did commit the crime of

20GRAND THEFT OF PERSONAL PROPERTY OVER $950.00 in violation of

21Section 487(a) of the Penal Code, a FELONY, who at the time and

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place last aforesaid, did willfully and unlawfully take money,23

labor and personal property of another of a value exceeding nine24

25 hundred fifty dollars ($950.00), to-wit: KENDALL WRIGHT, AN

26 INDIVIDUAL, $2,000.00 IN CASH ADVANCES.

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COUNT 11: GRAND THEFT OF PERSONAL PROPERTY OVER $950 PC.487(a)<F




Section 487(a) of the Penal Code, a FELONY, :aho at the time and

place last aforesaid, did willfully and unla~aiully take money,

labor and personal property of another of a Jalue exceeding nine

hundred fifty dollars ($950.00), to-wit: JESSIE MARTIN, DBA

PINNICLE WEB DESIGN, $2,000.00 FOR WEB DESI~?~I SERVICES.

For a further and separate cause of complai^:=, being a different



COUNT 12: GRAND THEFT OF PERSONAL PROPERTY OVER $950 PC.487(a)<F5







hundred fifty dollars ($950.00), to-wit: JEFF MARTIN, COMEDY

ENTERTAINER, $2,408.61 FOR COMEDY PERFORMANCES.

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statement of the same offense as the charges) above, complainant


COUNT 13: GRAND THEFT OF PERSONAL PROPERTY OVER $950 PC.487(a)<FSFEL







hundred °fifty dollars ($950.00), to-wit: CHRISTOPHER BENHAM, DBA

THE MEDIrS PLUS, INC., $3,000.00 FOR EVENT PREPARATION, SERVICES

DURING E~i~ EVENT AND BILLING AFTER THE EVENT .


statemer.~ of the same offense as the charge (s) above, complainant









hundred fifty dollars ($950.00), to-wit: ROBERT CASTILLO, DBA BMX

FREESTYLE TEAM, $8,357.00 FOR PERFORMANCES.

s.

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hundred fifty dollars ($950.00), to-wit: TINA t-=ASSERT, MASTER

HYPNOTIST, $5,000.00 FOR PERFORMANCES.

For a further and separate cause of complaint, ~~~ing a different




On or about May 15, 2014 - Ju1y 6, 2014, in the County of San






hundred fifty dollars ($950.00), to-wit: FRANCISCO SERRANO, DBA

SERRANO PRINTING ASSOCIATION, $4,891.92 FOR PRINTING SERVICES.

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Section 487(a) of the Penal Code, a FELONY, who at the time and


labor and ersonal property of another of a value exceeding nine

hundred fi~~:y dollars ($950.00), to-wit: TERRY ROBINSON, DBA DR.

SOLAR, $2,00.00 FOR PERFORMANCES.

For a furt-.=r and separate cause of complaint, being a different


further co:~:~lains and says


On or about June 17, 2014 - July 7, 2014, in the County of San






hundred fifty dollars ($950.00), to-wit: LA QUINTA HOTEL, A

BUSINESS, $2,721.64 FOR HOTEL ROOM CHARGES.

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AGGRAVATED WHITE COLLAR CRIME ENHANCEMENT PC.186.11(A)(1)

It is further alleged, pursuant to Penal Code 186.11(A), that the

offense (s) set forth in count (s) 1 through 18 are related felonies,

a material element of which is fraud and embezzlement, which

involve a pattern of related felony conduct, and the pattern or

related felony conduct involves the taking of more than one hundred

thousand dollars ($100,000.00).

TAKE,DAMAGE,DESTROY PROPERTY OVER $65,000 PC.12022.6(A)(1)

It is further alleged that in the commission of ~.he above offenses

in Counts 1 through 18, the said defendant (s) ME~~~%IN MONROE ADAMS

with the intent so to do, as part of a common scheme and plan, took

funds and property of a value exceeding $65,000.C'~ the property of

another, within the meaning of Penal Code Section 12022.6(a)(1) .

If the above-named defendants) is/are presently on probation in

San Joaquin County, any evidence presented at a preliminary hearing

in the instant case will be used not only as a basis for a holding

order in this case but also as evidence of a violation of probation

and, at any formal hearing on that violation of probation, the

People will move the transcript of the preliminary hearing into

evidence as a basis for the violation.

1 Pursuant to Penal Code Section 1054.5(b), the People hereby

2 informally request that the defendant and his/her attorney disclose

3 to the People all information and materials described in Penal Code

4 Section 1054.3.

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6I declare under penalty of perjury that the foregoing is true and

7correct except for those things stated on information and belief

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and those I believe to be true.9

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11 Executed on 6x'12/2015, at Stockton, California.

12 ' J J

13 -" r,..-

STEPHEN E. TAYLOR

14 Deputy District Attorney

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