I've recently been assigned to prosecute cases from H&HS for Welfare Fraud. In some cases, the Defendant has made false statements affecting benefits on more than one occasion throughout the course of a period of receiving benefits. Each false statement affects the total Restitution sought.

My question is whether I have to plead such situations as a "continuing course of conduct" or whether it is permissible to plead the date of the initial false statement.

It wouldn't be that difficult to plead the continuous course except that for some reason, H&HS has a different person take the statement each time and then execute the new form.

I just had a bunch of these come through and wasn't sure either. I had the H&HS supervisor send me the indictment language they wanted the cases prosecuted under.

I have proposed Indictments from the H&HS Investigators, but I'm not sure they are right.

Just charge it as a theft, cumulating all the conduct, and allege a period of time.

Thanks for the advice. All my single episode cases are being filed as SEDD, but the multiple episodes are being filed as Theft Aggregate. It really is the only way that makes sense for the latter.