D is a con artist. Gets people to rent equipment, buildings, perform services for him, etc. A LOT of money is supposed to change hands, but because D is a con artist it doesn't.
V's (there are 8 on this indictment) are out in excess of $200,000. (Aggregate). Mostly for bad checks, some theft of service, property and damage to property. Somehow theft doesn't seem severe enough a charge. Anybody got any ideas on alternate charges for this guy?
Any of your victims elderly? If so, under TxPC 31.03(f)(3) you can bump the degree up one level. I don't know if you can get away with aggregating elderly & non-elderly victims, though. Looks like you've got plenty of loss to get a pretty good punishment on the perpetrator, though. Priors?
Can you get a better punishment by severing the victims' losses and stacking?
By chance, did he use the mail at any time to execute part of his scheme?
I got him to a 1st w/aggregation. I don't think we could get more with stacking.
He did use the mails, but the feds have declined.
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