Have a theft case (and Misapplication as well) where victims invested money in corporation from 4/18/2005 through 9/29/2005. The bookkeeper, not an officer, starts stealing money on 8/2/2005 and keeps on till 12/11/2007. It is a continuous scheme and course of conduct and third degree amount. WHAT DATES:
1)paragraph for each victim with their date of investment (which does not cover all the dates of the theft)
2) take one victim with over $20,000.00 investment with cont scheme over period of time
or
3) ??? suggestions?
Thanks

A couple of observations:

1. If the money was invested in a corporation (a separate legal entity), then the theft will be from the corporation and not from the individual investors (who I assume either issued loans or purchased shares of the corporation)

2. That being the case, I would think the proper way to structure the indictment would be to name the president or treasurer of the corporation as the victim and to allege each theft as a theft from the corporate officer. That way you can allege all of the thefts involved and aggregate them to get the highest offense and greatest amount of restitution.

3. This way also allows you to minimize your witnesses at trial and have one "victim" to present to the jury/judge.

If the corporation is the victim, you could also allege a date range and put it all in one paragraph: from (date) through (date), etc. Email me if you need a sample.

Thanks for the help guys!! I do have the date range form, as I originally indicted the case with the corporation as the victim. However, my corporation is questionable, as they were selling something that could have been a scam. That is why I wanted to use the investors as victims.