l.a. coliseum corruption -- petition, indictment and motions in the criminal case

MOTION TO CONDUCT A HEARING PURSUANT TO PENAL CODE § 1275.1

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STEVE COOLEY District Attorney MAX HUNTSMAN Deputy District Attorney State Bar No. 156780 PUBLIC INTEGRITY 320 W TEMPLE STREET RM 766 LOS ANGELES, CA 90012 (213) 974-6501 Attorney for Plaintiff

SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES

PEOPLE OF THE STATE OF CALIFORNIA,

Plaintiff, v.

01 Todd DeStefano, 02 Pasquale Rotella 03 Reza Gerami 04 Patrick Lynch 05 Antonio Estrada 06 Leopold Caudillo

Defendants.

Case No.: BA396065 MOTION TO CONDUCT A

HEARING TO DETERMINE THE LEGITIMACY OF PROFFERED BAIL PURSUANT TO PENAL CODE § 1275.1

TO THE HONORABLE JUDGE IN DEPARTMENT 100; THE DEFENDANT, AND

HIS ATTORNEY OF RECORD:

PLEASE TAKE NOTICE that the People request the Court to conduct a hearing to

determine legitimacy of proffered bail, pursuant to Penal Code Section

1275.1.

THE PEOPLE ALSO REQUEST THAT the court place a hold on the release of all

defendants listed above from custody until such a hearing may be conducted.

This motion will be based upon the attached points and authorities, declarations filed in support


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of this motion and pleadings, records, files, documents, and evidence, oral or written, to be

presented at the hearing on this motion.

Dated: March 20, 2012 Respectfully submitted,

STEVE COOLEY DISTRICT ATTORNEY By Max Huntsman Deputy District Attorney Attorney for Plaintiff


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POINTS AND AUTHORITIES

Penal Code Section 1275 states:

"[In fixing the amount of bail,] the judge or magistrate shall take into consideration the

protection of the public, the seriousness of the offense charged, the previous criminal

record of the defendant, and the probability of his appearing at the trial or hearing of the

case.

Penal Code Section 1275.1 states:

No bail bond shall be accepted unless the judge or magistrate be convinced that no

portion of the consideration, pledge, security, deposit, or indemnification paid, given,

made, or promised for its execution was feloniously obtained by the defendant."

(Emphasis added.)

Penal Code Section 1275.1(b) authorizes the judge to place a hold on the release of the defendant

from custody when a peace officer or prosecutor declares under penalty of perjury that he

has probable cause to believe that the consideration for the bail was feloniously obtained.

Penal Code Section 1275.1(c) indicates that, at the hearing, the defendants bear the burden of

proving by a preponderance of the evidence that no part of the consideration, pledge,

security, deposit or indemnification for the bail was feloniously obtained.

The mere proffering of a corporate surety bond in the amount set at bail does not deprive the

Court of the right to inquire into areas which might bear on whether the defendant will

make future court appearances if released on bond. United States v. Ellis De Marchena,

330 F. Supp 1223 (1971) (Affirmed, Dkt. No. 71-2343. September 3, 1971, 9th Cir.).

The Court has the right and duty to satisfy itself that there is more than just a financial

assurance that a bailed defendant will appear in court when required . . . . The source of

the security providing the collateral for the bond can provide valuable information


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regarding the motivation for a defendant to appear. If the bond were secured by the

property of defendant's relatives, or close friends, the court could, logically, conclude that

the possibility of financial harm to those individuals might motivate a defendant to

appear. On the other hand, if the security comes from an illegitimate source, and is

merely a 'business' expense for a dealer in contraband, there is a paucity of moral force

compelling a defendant to reappear. Indeed, such a source would be more consistent with

a possible fulfillment of a pledge to a defendant of purchased freedom if caught." United

States v. Ellis De Marchena, 330 F. Supp 1223 (1971) (Affirmed, Dkt. No. 71-2343.

September 3, 1971, 9th Cir.). (Emphasis added.)


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DECLARATION IN SUPPORT OF MOTION TO CONDUCT A HEARING

PURSUA 1275.1NT TO PENAL CODE SECTION

I, Deputy District Attorney Max Huntsman, declare as follows:

1. That I am a deputy district attorney assigned to the investigation and prosecution of

Todd DeStefano, Pasquale Rotella, Reza Gerami, Patrick Lynch, Antonio Estrada, and

Leopold Caudillo. That investigation has included review of investigation conducted by the Los

Angeles Memorial Coliseum Commission, interviews of witnesses, service of search warrants,

review of bank records, and grand jury testimony

2. Todd DeStefano was an employee of the Los Angeles Memorial Coliseum

Commission since prior to 2006. His title began as “Assistant General Manager.” His official

duties included substantial influence over all aspects of Coliseum business, particularly

marketing and planning of events. In 2009 his title changed but his job duties did not.

3. Pasquale Rotella owns a company called Insomniac which has produced electronic

music concerts, or “raves,” at the Los Angeles Memorial Coliseum between 2008 and 2010.

Reza Gerami owns a company called Go Ventures which has produced electronic music

concerts, or “raves,” at the Los Angeles Memorial Coliseum between 2008 and 2010.

4. Patrick Lynch was an employee of the Los Angeles Memorial Coliseum Commission

since prior to 2006. His title was “General Manager.”

5. Antonio Estrada owned a company called “Services For All Events” which provided

clean up services to the Coliseum from 2006 to 2011.

6. Leopold Caudillo was employed by the Coliseum to provide technical services and

controlled a company called “HH Tech” from 2008 to 2010.

7. That after a review of the facts in this matter, I believe that the defendants obtained

public funds in violation of Penal Codes 182, 487, 504, 68, and Government Code section 1090.

Mr. DeStefano received at least $1,891,680 feloniously from Rotella and Gerami and an

additional $240,000 from third parties through the fraudulent use of his company “LAC Events.”


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Rotella and Gerami obtained unlawful contracts through their bribery of DeStefano resulting in

profits of millions of dollars. Lynch received $385,500.41 from Estrada in the form of checks

labeled “Events Consultant” while determining the amount of public funds paid to Estrada’s

company. Estrada received payments on millions of dollars of invoices while making regular

payments to Lynch.

8. In July of 2006, Lynch directed Financial Director Ron Lederkremer to increase the

amount paid to Estrada for services provided to the Coliseum. From August of 2006 until the

beginning of 2007, Estrada wrote regular checks to Lynch and Lynch deposited them in his

personal account. The checks carried the notation “Events Consultant.” In February of 2007,

Lynch created a Miami bank account using a Miami address at which he did not live and

providing for a signature stamp to be an authorized signature. Thereafter Estrada deposited the

checks directly in to this account. When asked by an investigator for the Coliseum, Lynch

denied the arrangement and said the account was a joint one with Estrada that Estrada claimed

was created to pay a workers’ compensation claim. Lynch denied any agreement to receive a

portion of public funds paid to Estrada, but admitted that Estrada had proposed such an

arrangement. A draft contract between Estrada and Lynch to be partners in Estrada’s company

and for “monthly consulting payments” was found on Lynch’s computer. The payments from

Estrada continued through 2011 and totaled $385,500.41.

9. From 2008 until 2010, Mr. DeStefano received at least $1,891,680 feloniously from

Rotella and Gerami. Mr. Rotella paid at least $1,175,000 during this period and Mr. Gerami

paid at least $716,680.

10. In 2008, Mr. DeStefano appears to have drafted unsigned agreements with Rotella

and Reza Gerami which provided that he would be paid personally for the use of the Coliseum

and for his assistance in keeping costs down. In 2010 Mr. DeStefano emailed a copy of one of

these agreements to Rotella and referred to it as the agreement they had entered in to years

earlier. Also in 2010, Mr. DeStefano emailed a copy of one of the agreements to Gerami and

referred to it as the agreement they had talked about years earlier.


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11. In January of 2010, DeStefano wrote an email to Gerami stating that rent for an event

would be “only” $25,000. He further stated that he had made the arrangement with “Pat”

(Patrick Lynch) but that “Ron” (Ron Lederkremer) did not know yet. DeStefano stated he had

changed line items and that $60,000 would be wired to Gerami (the Coliseum disbursed profits

from events after the event was complete). DeStefano asked that the money be wired to him.

Bank records reflect that Go Ventures made an electronic deposit of $60,000 to DeStefano on

January 20, 2010.

12. On March 30, 2010, Gerami wrote four checks to DeStefano totaling $194, 970.76.

They had the following notations written on them: “Venue/Rent/MM09 Final”, “MM10/In Ref.

to Check 5819/Venue Rent”, “Venue Rent/ TAO 10”, “Rent/Venue/TAO 10.” DeStefano

deposited the checks on April 8 and April 16, 2010.

13. On April 21, 2010, Rotella wrote a check to DeStefano in the amount of $50,000 with

the notation, “EDC 09 LA – Venue Use Fee / Balance.” DeStefano cashed it on April 23, 2010.

14. As part of his official duties, DeStefano regularly represented the Coliseum in

planning meetings for the events put on by Rotella. Rotella and Gerami were regularly present

as well. DeStefano, Rotella, Gerami, and Lynch never disclosed the payments while DeStefano

was influencing the contracts. DeStefano actively participated in the decision making processes

regarding Rotella’s and Gerami’s contracts at all stages.

15. In 2009, Lynch told Commission Counsel Donovan Main that DeStefano was

considering doing outside work for promoters in the future. Main told him he could not give an

oral opinion on the subject, but warned Lynch that conflict of interest law was broad and

DeStefano could have no involvement in any promoter’s events while being paid for them.

Lynch told Main that any outside employment would be accompanied by a “firewall” to keep

DeStefano from being involved in events for promoters from whom he was receiving money.

Lynch allowed DeStefano to continue to run Insomniac and Go Ventures events while being paid

by them.

16. Between 2006 and 2010, DeStefano embezzled funds due the Coliseum from a


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number of businesses in addition to Insomniac and Go Ventures. In 2006, DeStefano entered in

to a contract with Dreamworks to allow the company to conduct filming on “Blades of Glory” at

the Sports Arena in exchange for paying $74,000 to “LAC Events” and kept the money. In 2008,

DeStefano directed AM GLAD Productions to write half of a $100,000 deposit for a second

season of filming “American Gladiators” at the Coliseum to “LAC Events” and kept the $50,000.

In 2010, DeStefano drafted an agreement for the Coliseum to sell products from Southern Wine

and Spirits but kept three checks totaling $49,500 made out to “LAC Events Inc.” On November

18, 2010, DeStefano deposited a check for $70,000 from Coca-Cola in his company’s account in

exchange for the Coliseum committing to an exclusive marketing and sales deal with Coca-Cola.

Lynch and DeStefano planned this diversion of funds together and Coca-Cola was told to cancel

a check initially written to the Coliseum and make one out to DeStefano’s company instead.

17. In the summer of 2010, rave safety became a particularly public issue. LAPD

recommended external cameras at unmanned Coliseum gates and DeStefano said they would be

provided. They were cancelled shortly before the Electronic Daisy Carnival. Subsequent to the

death of an audience member after this event, DeStefano actively worked behind the scenes to

influence the Coliseum Commission to allow raves to continue. During this process none of the

people aware of the illegal payments (DeStefano, Lynch, Rotella, and Gerami) disclosed to the

Coliseum Commission that DeStefano was being paid by promoters while advising them to

proceed with raves in the future.

18. In July of 2010, DeStefano was solicited by Bernard Parks Jr. to obtain campaign

contributions for Commissioner and Council candidate Bernard Parks. DeStefano emailed the

contribution form to Gerami and Rotella and asked them both to donate $500 and to provide him

with $10,000 for a fireworks show hosted by Parks.

19. In July of 2010, DeStefano emailed Rotella a copy of a report prepared by Coliseum

attorneys before it was public. The email had the subject heading “confidential” and directed

Rotella to make sure he did not copy anyone.

20. As part of his official duties, DeStefano advised Commission members on the


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feasibility of raising rents on the events put on by Rotella and Gerami. The Commission relied

on his advice without being informed of the $1.9 million dollars he had received or his

agreement to keep expenses “tight.”

21. In September of 2010, while DeStefano was using his inside influence to benefit

Rotella and providing information to Rotella, Rotella directed a wire transfer of $300,000 to

DeStefano.

22. In January of 2011, DeStefano admitted to a Coliseum investigator that he had been

paid by promoters for events at the Coliseum, but claimed he had only received money from

Insomniac for the Electric Daisy Carnival in 2010. He denied ever receiving funds from Go

Ventures.

23. Between 2008 and 2010, Leopold Caudillo caused over $20,000 of public funds to be

paid to HH Tech without disclosing that the funds were then paid to him from the company

which he controlled.

24. Because of the substantial amount of feloniously obtained funds and the length of

time over which they were obtained, I believe a portion of any pledge, consideration, security,

deposit, or indemnification presented by DeStefano, Rotella, Gerami, Lynch, or Estrada for bail

would be feloniously obtained.

25. That compliance with Section 1275.1 of the Penal Code by the Court would be

facilitated by a hearing to determine that the source of any proffered bail was not feloniously

obtained.

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26. The information contained herein is based upon interviews of witnesses conducted

by me, review of police reports and subpoenaed documents, and the taking of testimony before

the grand jury resulting in the indictment in this case.

I swear under penalty of perjury that the foregoing is true and correct to the best of my

knowledge.

Executed this March 20, 2010 at LOS ANGELES, California.

__________________________

Declarant

PETITION TO FREEZE (PC 186.11) - 1

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STEVE COOLEY, District Attorney MAX HUNTSMAN, Deputy District Attorney JENNIFER LENTZ SNYDER, Assistant Head Deputy Public Integrity Division 320 West Temple Street, Room 766 Los Angeles, CA 90012 (213) 974-6501 Attorneys for Plaintiff

SUPERIOR COURT FOR THE COUNTY OF LOS ANGELES

STATE OF CALIFORNIA

PEOPLE OF THE STATE OF

CALIFORNIA,

Plaintiff,

vs.

TODD DESTEFANO , PASQUALE ROTELLA, REZA GERAMI, PATRICK LYNCH, ANTONIO ESTRADA and LEOPOLD CAUDILLO, Defendants

) ) ) ) ) ) ) ) ) ) ) ) ) )

Case No.: BA396065 PEOPLE'S PETITION TO FREEZE ASSETS WITHIN CONTROL OF DEFENDANTS, AFFIDAVIT OF DEREN BRADY, SCHEDULE OF ASSETS, PROPOSED NOTICE AND ORDER TO SHOW CAUSE (PENAL CODE SECTION 186.11)

TO THE HONORABLE JUDGE OF THE LOS ANGELES COUNTY SUPERIOR

COURT:

The People of the State of California, by and through the Los Angeles County

District Attorney, petition this court for an order freezing identified asset that are in the

control of the defendants, pursuant to Penal Code Section 186.11(d)(2).

By indictment filed at or before the filing of this petition, defendants are charged

with a series of crimes including bribery, embezzlement, and conflict of interest, which

involve the diversion of more than $2.5 million from the Los Angeles Memorial Coliseum


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to the personal accounts of defendants DeStefano and Lynch, who were, at the time

these crimes were committed, employed by the Coliseum.

As set forth in the Declaration of Investigator Deren Brady, which is attached to

this petition, a material element of these crimes is fraud and embezzlement from the

Coliseum, as demonstrated by the acts of defendants DeStefano and Lynch, who

received payments and kickbacks from Coliseum vendors and event promoters,

including defendants Gerami and Rotella. Defendants Gerami and Rotella paid

DeStefano in excess of $1.8 million in order to continue to hold the events they

promoted at the Coliseum through contracts that DeStefano negotiated to the benefit of

the promoters, thereby saving them significant sums of money, and to the detriment of

the Coliseum which lost revenue by the reduced costs as well as the payments diverted

to DeStefano’s personal business accounts. Rotella and Gerami paid DeStefano to

directly lobby for them to save them at least $1 million by virtue of his position as a

Coliseum insider who affected the contract for their events and the amount of rent paid

to the Coliseum. Lynch became aware of the relationship and allowed it to continue.

Additionally, some companies were led to believe that DeStefano’s company, Los

Angeles Coliseum Events, was part of the Los Angeles Memorial Coliseum when in

fact, it was not. As a result, those companies paid DeStefano’s company for the right to

to film, sell products and advertise at the Coliseum when the right to grant such licenses

and any payment thereon rightfully belonged to the Coliseum.

These crimes involve related felony conduct because they involve the same

victim and a similar scheme, namely to divert money to which the Coliseum was entitled

to defendants’ personal interests. Finally, the amount of loss resulting from the

commission of these crimes exceeds $2.5 million.


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Also attached is a schedule of assets believed to be in the control of the

defendants, including a description of the specific asset, the nature of the asset, its

value, the basis of its valuation and the date of valuation.

As set forth in the declaration of Investigator Brady, there is a significant risk that

these assets may be dissipated during the pendency of this action, thereby threatening

the victims ability to recover restitution, to which the victim is constitutionally entitled

when defendants are convicted of the crimes charged herein.

The People therefore ask that this court issue a temporary restraining order

protecting the identified assets during the pendency of this case, thereby prohibiting the

transfer, encumbrance or hypothecation of any of the assets listed until further order of

this court. A proposed Notice, Temporary Restraining Order, Lis Pendens and Order to

Show Cause, in compliance with Penal Code Section 186.11 is submitted for this court’s

consideration. By its terms, the order seeks to protect the status quo of the property

listed therein and provide notice to any present or subsequent interest holder of the

pendency of this action. With regard to the real property assets, the Notice, orders and

lis pendens will be filed and recorded with the recorder of the county in which the real

property is located as soon as investigators obtain a conformed copy of the court’s

signed order.

The People will provide notice of this court’s order, and instructions regarding the

filing of a verified claim, by certified mail, by personal service, and/or by publication as

required by Penal Code Sections 186.11(d)(3), and (4) to any and all potential interest

holders in the property listed in the order in a timely matter. Finally, the People request

that this court direct the banking or financial institution to immediately disclose the

account numbers and value of the assets of the accused held by the banking or

financial institution, pursuant to Penal Code Section 186.11(d)(5).


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DATED: March 22, 2012 Respectfully submitted,

STEVE COOLEY District Attorney By MAX HUNTSMAN Deputy District Attorney JENNIFER LENTZ SNYDER Assistant Head Deputy Public Integrity Division


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AFFIDAVIT IN SUPPORT OF ORDER TO SHOW CAUSE

AND TEMPORARY RESTRAINING ORDER

I, Deren Brady, declare:

I am a Senior Investigator for the Los Angeles County District Attorney’s Office,

Bureau of Investigation. I have been a peace officer in the State of California for over

sixteen years: five years for the Los Angeles County Sheriff’s Department, and eleven

years as an investigator for the Los Angeles County District Attorney’s Office, Bureau of

Investigation. I am currently assigned to the Public Integrity Division.

I am the lead investigator in the case of People vs. Todd DeStefano, et al, case

number PID Case 11-0087. As such, I have personal knowledge of the facts set forth

herein, and if called upon, could and would competently testify thereto.

Defendants Todd DeStefano, Patrick Lynch, Reza Gerami and Pasquale Rotella

have been indicted in case BA396065. Defendants have been charged with Conspiracy

to Commit Embezzlement, Embezzlement, Bribery, Receipt of Bribes, and Conflict of

Interest. Defendants are further charged with the enhancements pursuant to Penal

Code Sections 12022.6(a) (loss exceeding $1,300,000) and Section 186.11,

"aggravated white collar crime" enhancement.

The defendants are charged with more than two felonies, a material element of

which is fraud or embezzlement. The crimes charged are related by virtue of the fact

that the crimes were committed against the same victim, the Los Angeles Coliseum.

The crimes involve fraud and embezzlement. The defendants diverted money paid by

companies seeking to do business with the Coliseum into the personal and business

accounts of defendant DeStefano. Other counts involve the payment of bribes by


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defendants Gerami and Rotella to DeStefano and his personal businesses, Los Angeles

Coliseum Events (“LACE”) and Private Events Management. The evidence

demonstrates that defendant Lynch facilitated the payments to DeStefano, and

collected more than $385,000 in kickbacks over a five year period, paid to him by the

owner of a company that provided clean up services for events held at the Coliseum.

The losses caused by the charged criminal conduct total $2,520,180. A

breakdown of the losses is described in greater detail is on page of this affidavit.

The crimes as charged and as more specifically described herein are felonies, a

material element of which is fraud or embezzlement, which involve a pattern of related

felony conduct that resulted in the taking or loss by the Coliseum of more than $2.5

million. Based on the evidence I have reviewed, I strongly believe that the crimes

alleged in the indictment constitute aggravated white collar crimes as defined by Penal

Code Section 186.11.

I have been advised that Penal Code Section 186.11 allows the Superior Court to

preserve any asset or property that is in the control of the defendants, up to three times

the value of loss or taking until the conclusion of the criminal prosecution. Upon

conviction, the assets may be levied upon by the Superior Court to pay restitution to the

victims of the alleged crimes and to pay fines imposed pursuant to Section 186.11(c).

The statute permits a fine equal to twice the amount of restitution to be imposed. Penal

Code Section 186.11(e)(1).

The amount of restitution and fines established by Penal Code 186.11 permit this

court to freeze assets in the control of defendants up to three times the value of the

loss.


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The worth of the assets of Todd DeStefano sought to be frozen is estimated to

be $535,981.44. The maximum value of DeStefano’s assets that may be frozen, three

times $2,065,250.00 is $6,195,750.00, which exceeds the worth of the assets of

defendant DeStefano that are sought to be frozen.

The worth of the assets of Patrick Lynch sought to be frozen is estimated to be

$1,425,255.77. The maximum value of Patrick Lynch’s assets that may be frozen, three

times $2,347,180.41 is $7,041,541,23 which exceeds the worth of the assets of

defendant Lynch that are sought to be frozen.

The worth of the assets of Pasquale Rotella sought to be frozen is estimated to

be $1,754,020.86. The permissible value of Pasquale Rotella’s assets that may be

frozen, three times $1,175,000.is $3,525,000.00 which exceeds the worth of the assets

sought to be frozen.

The worth of the assets of Reza Gerami sought to be frozen is estimated to be

$372,624.13. The permissible value of Reza Gerami’s assets that may be frozen, three

times $716,680.00 is $2,150,040,00, which exceeds the worth of the assets sought to

be frozen.

The total value of all assets sought to be frozen thus far is estimated to be

$4,094,122.20. However, this total is based upon balances from bank and investment

accounts that have not been updated since the financial documents were obtained

pursuant to search warrant during the course of this investigation. Consequently, I

believe that it is highly likely that the total value is actually substantially less than is

reflected by the asset schedule. Additionally, current information will be sought

immediately upon the issuance of the freeze order so that accurate, current balances


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and values may be determined. That information will be immediately conveyed to the

court.

SUMMARY OF CASE

The Los Angeles Memorial Coliseum and Sports Arena are publicly owned and

operated venues. During the time the charged crimes were committed, defendant

Patrick Lynch was the general manager of the Los Angeles Memorial Coliseum and

Sports Arena (Coliseum). Defendant Todd DeStefano was the assistant general

manager of the Coliseum. As such, these defendants were in charge of the operations

involving the Coliseum. Both were public employees of the Coliseum and were paid by

the City of Los Angeles.

As general manager, defendant Lynch was responsible for overseeing the

operation of the Coliseum and Sports Arena. Lynch had the authority to hire and fire

employees, hire contractors and to determine how much they would be paid. He

approved the final contracts entered into by the Coliseum with promoters and vendors.

Defendant DeStefano ran the day to day operations for events at the Coliseum

and Sports Arena. DeStefano personally negotiated as the Coliseum’s representative

on many aspects of the Coliseum’s contracts with event promoters and vendors, and

had primary responsibility for establishing and overseeing the execution of the

contracts. While his job title changed in 2009, his duties and responsibilities did not.

In addition to his position with the Coliseum, DeStefano operated a company

called Los Angeles Coliseum Events (“LACE”). According to public records, LACE (also

known as “LAC Events”) and Private Event Management are private companies owned

by DeStefano. Statement of economic interest reporting forms, commonly called Form


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3 • LAC Events from January 1, 2007 to November 7, 2007.

8 • LAC Events, LAC Events (spouse’s income) Go Ventures, Insomniac and

Takeda Pharmaceuticals North America, Inc (spouse’s income) from January 1,

2009 to December 21, 2009.

700s, filed recently by DeStefano through his attorney, and bearing a signature date of

April 27, 2011 list income from the following companies for the following periods:

• LAC Events, Toole of North America, University of California, American Carol,

AM Glad, Go Ventures and Insomniac from November 8, 2007 to December 31,

2008.

• LAC Events, Private Events Management, LAC Events (spouses income),

Private Events Management (spouses income), University of California, Southern

Wine, Coca-Cola, Go Ventures, Insomniac and Takeda Pharmaceuticals North

America, Inc (spouses income), January 2010 to January 21, 2011.

DeStefano is listed on the forms as the President of LAC Events and Private

Events Management, which are entertainment/event promotion companies. The

business addresses are identified on the forms for LAC Events as 2202 S. Figueroa

Street, Los Angeles, California 90007 and Private Events Management as 1612

Hastings Heights, Pasadena, California 91107. I have determined that the address on

Figueroa is a UPS Store with mailbox facilities. The address on Hastings Heights in

Pasadena is DeStefano’s former residence. I conducted a search of databases through

Lexis Nexis, which reflects corresponding information regarding the ownership and

location of these entities.


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Defendants Pasquale Rotella and Reza Gerami are the owners of event

promotion companies Insomniac and Go Ventures respectively. These companies

promote and hold “Electronic Music Festivals” which are often referred to as “raves”

throughout the country. The Coliseum was one of the locations where these events

were held. Promoters are charged a rental fee for use of the Coliseum facilities, and

are bound by contract with the Coliseum to paying all costs associated with the event,

including off duty Los Angeles Police Department Officers, Los Angeles City Fire

Department Fire and Emergency Medical Personnel, private security, ushers and ticket

takers and janitorial service, to name a few. The planning of the events includes

personnel from all the entities, both public and private, that will be involved. In most

cases, the planning and negotiating process for the final number of personnel needed

for the event is conducted by the promoter and a representative of the venue. The

Coliseum has the final word with regard to the services and personnel that will be

required for an event to be held, with the exception of deployment of city fire and police

on duty personnel. Most revenue is collected by the Coliseum, which then deducts the

rental amount and any other fees owed to the Coliseum, and then transmits the balance

to the vendor.

Insomniac is the promoter for the “Electric Daisy Carnival” (“EDC”), an event that

has been held at the Los Angeles Coliseum. Insomniac, as the promoter, was

responsible for paying all expenses associated with holding the event at the Coliseum.

Go Ventures was the promoter for the yearly Monster Massive and Together as

One (rave events) which are events that were held at the Coliseum. Together as One is


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an electronic music festival promoted by Insomniac and Go Ventures. The events were

primarily run by Gerami.

DeStefano was responsible for establishing the terms of the contracts between

the promoter of an event and the Coliseum, which would include the services that were

required by the Coliseum to be provided by the promoters in order for their event to be

held at the facility. This included coordination of services provided by LAFD, off duty

LAPD personnel, private security, safety requirements, staging and striking staging, and

other logistical requirements.

For instance, in an interview with Los Angeles City Fire Department (LAFD) Fire

Inspector John Benn, I learned that Benn has been a fire inspector for approximately 12

years and has been part of the event planning aspect for around five years. His current

assignment is with the Public Assemblage (PA) Unit, which is responsible for

establishing occupancy loads for events (maximum capacity) held in the City of Los

Angeles. He told me that initial conversations for the 2010 EDC event began

approximately eight to ten months prior to the June 2010 EDC event. Benn dealt with

Insomniac’s CEO, Pasquale Rotella from the promoting aspect of the planning and

requirements. Benn dealt with DeStefano as the point person for the Coliseum, and day

to day operational needs. Any changes needed by LAFD for the venue would go

through DeStefano. Rotella and DeStefano would meet and then tell LAFD what they

wanted to do for the EDC (i.e. stage locations, performances, etc.). LAFD would then

tell them what would be required to make the proposed plan work.

I interviewed Contemporary Services Corporation (CSC), Branch Manager Roy

Sukimoto. Sukimoto has been working with Contemporary Services Corporation since


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1973. CSC has been contracted with the Coliseum since 1988. Sukimoto supervises

approximately three thousand employees consisting of security officers, ticket takers

and ushers. Initial conversations for the EDC event began approximately three to four

months prior to the June 2010 EDC event. To determine staffing levels needed for the

EDC event, Sukimoto needed the “footprint” of the event. The footprint consists of the

estimated attendance, entrances, exits, stage locations, etc. The footprint was provided

by DeStefano and/or the promoter, Insomniac. Insomniac is responsible for supplying

the final blueprint (plans) for the EDC event which must be approved by the LAFD.

DeStefano was the point person who represented the Coliseum for the EDC event with

Insomniac, LAPD, LAFD, EMS, CSC and all other entities involved with staging the

event. Sukimoto provided DeStefano with his estimate/recommendations for CSC

which required approval and review by Insomniac, LAPD and LAFD. CSC provided a

personnel and cost estimate based on the numbers provided to them by Insomniac.

DeStefano had an influence on the total staffing numbers to be provided by CSC, which

was part of his responsibility for the event. All budgeted proposals were done on paper

and a revision was made if any changes were made. Any proposed changes from

Insomniac would be channeled through the Coliseum representative, DeStefano. All

phases of the EDC event planning were channeled through DeStefano.

I interviewed LAFD Captain Keith Douglass. Douglass has been with LAFD for

approximately 28 years. Douglass is also a Paramedic and oversees the Emergency

Medical Services Division (EMS). For the past four years Douglass has been in charge

of the EMS medical planning for major public events. Prior to the 2010 EDC event,

EMS was part of approximately ten to twelve pre-planning meetings for the EDC. EMS


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would set necessary medical components based on the statistics from previous events.

The factors involved included, number of expected attendance, risk factors associated

with the type of crowd, past medical services rendered, etc. DeStefano represented the

Coliseum’s interest in the EDC event planning. DeStefano was the go between for the

Coliseum and EMS and was very in tune with the day to day operations of the

Coliseum. Douglass would meet with DeStefano and determine the number of EMS

personnel needed for the EDC event based on numbers from previous statistics and

risk factors. Any negotiation would be based on the data provided by DeStefano. All

negotiations for resources went through DeStefano and Insomniac to support the EMS

plan. EMS also deployed foot patrol paramedics. The Coliseum has a private contract

with EMTs inside the Coliseum. DeStefano had influence on the number of Coliseum

EMTs used. Based on the number of Coliseum EMT’ deployed, Douglass would

determine the number of LAFD Paramedics and ambulances needed.

I also interviewed past and current employees of the Coliseum who told me

DeStefano was the person from the Coliseum responsible for planning and negotiating

contracts for these events.

I interviewed Los Angeles Memorial Coliseum Director of Finance Ronald

Lederkramer. Since the time of the interview in 2011, he has left the employ of the

Coliseum. Lederkramer was with the Coliseum for approximately 15 years.

Lederkramer was Director of Finance in addition to being the Assistant General

Manager (GM). His responsibilities included financing, budgeting, billing, banking,

promotions, event contracts and settlements.


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Approximately five years ago, Lederkramer began sharing his role as Assistant

GM with DeStefano. DeStefano worked for the Coliseum for approximately 7 years

before he was promoted by GM Lynch to Assistant GM. DeStefano was in charge of

events, sponsorships and advertisements. DeStefano resigned at the beginning of

2011. Lederkramer believes the reason Lynch promoted DeStefano was to prevent him

(Lederkramer) from supervising and watching DeStefano’s activities. Accounting

procedures changed with DeStefano in this position. Generally accounting settlements

would be seen by the finance department and any changes would be made prior to the

bill going to the promoter. DeStefano operated differently. DeStefano would show the

bill to the promoter prior to bringing it to the finance department for a final stamp of

approval. Changes could not be made at this time because DeStefano had already

agreed with the promoter on the final billing.

Lederkramer provided me with copies of the Event Billing/Invoice Reports.

DeStefano was involved with the technical day to day operations and event planning.

Near the end of February or early March 2011, Lederkramer met Rotella for a

beer at Houston’s Restaurant in Century City. Rotella told him that he paid DeStefano

$500,000 for the EDC event in 2010. Rotella thought he would not be able to hold the

event at the Coliseum if he did not pay DeStefano. He was under the impression

DeStefano and Lynch controlled the Coliseum Commission and DeStefano’s company,

LAC Events had rights to the Coliseum. Lederkramer explained to Rotella that there

was no an additional fee required for the Coliseum usage. Rotella paid DeStefano

between $125,000 and $250,000 for the EDC event in 2008 and $250,000 for the EDC


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event in 2009. Rotella paid DeStefano by check and provided him with 1099’s. Rotella

told Lederkramer he paid DeStefano in order to hold his events at the Coliseum.

DeStefano made the decisions for all the planning of the EDC event. He had

total control of the number of personnel used and the expenses for the EDC event.

DeStefano could not influence the LAFD Inspectors requirements or the on duty LAPD

area deployment, but did decide on the number of private security company personnel,

off duty LAPD Officers and EMT personnel. According to Lederkramer, the final

contract for the event was approved by Lynch.

At the conclusion of the EDC event, the Coliseum made payments to Insomniac

by check or wire transfer. The Coliseum deducted the rent and expenses for the EDC

event and forward the remainder of the proceeds to Insomniac.

Lederkramer also told me about Go Ventures and its owner, Reza Gerami.

According to Lederkramer, DeStefano dealt with was Reza Gerami on events promoted

by Go Ventures. The final contracts were approved by Lynch.

According to Lederkramer, DeStefano directly influenced the amount of revenue

received by the Coliseum for rent for these events. DeStefano argued strenuously for

reduced rental rates for the rave promoters, Gerami and Rotella, even though the gross

amount of money generated by these events steadily increased over the years.

Lederkramer provided me with a chart of two Go Ventures events showing the

attendance, gross ticket sales and rent received by the Coliseum. The revenue

increased and the rent decreased. Notably, DeStefano only argued for the rent

reduction from the “Raves,” but not on behalf of other events. Lynch agreed to the

reduced rents .


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In July of 2009, Lynch told Lederkramer and other staff members DeStefano

would be getting paid by the promoters and that the Coliseum Commission was aware

of this arrangement. Previously, staff members would be paid a commission based

upon the business they brought into the Coliseum. Because he was getting paid by the

promoters, commission normally paid by the Coliseum to DeStefano for the rave events

would be discontinued, according to Lynch. Lederkramer believes the Coliseum

Commission knew DeStefano was getting paid by promoters for outside events, but

does not believe that the Commission knew that DeStefano was actively working on

behalf of the Coliseum on the same events he was working on behalf of the promoters.

Lederkramer recalled that he had lunch with DeStefano and DeStefano told him, “if you

guys don’t have to pay me, Reza will.”

Lederkramer believes DeStefano made Go Ventures and Insomniac more

profitable at the expense of the Coliseum because the promoters paid a reduced fee for

use of the Coliseum, and their costs were lower because DeStefano worked to save

them from having to incur costs.

An unsigned contract between DeStefano’s company, Los Angeles Coliseum

Events (LACE), Insomniac, and Go Ventures was found at DeStefano’s residence

during the execution of a search warrant.. The same contract was found on the

computers of Rotella (Insomniac) and Gerami (Go Ventures) during search warrants

conducted at their residences and businesses. The agreement gave DeStefano 10% of

the gross tickets sales, while requiring him to keep all cost associated with the events

“as tight as possible.” The agreement established that, if the Coliseum increased the

rent for the events at any time, LACE (DeStefano’s private company) was responsible


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for paying the difference. Events are described in the document as “any and all

Electronic DJ shows including but not limited to: Electric Daisy Carnival, Love Festival,

Monster Massive, Together as One, and any other yet to be determined Electronic

Music Festival held in Exposition Park.” Exposition Park includes the Coliseum, Sports

Arena and surrounding grounds. The agreement specified that LACE would oversee

and be in charge of all necessary personnel and services connected with the events

(i.e. Police, Fire, EMT, security etc). There is also a concession/sponsorship clause

that paid LACE 15% commission on any deals brought into the event.

The evidence suggests that the reduced rental rates and other contractual terms

beneficial to the promoters were supported by DeStefano to ensure that his company,

LACE, would continue to get paid by the promoter, even though the reduction in rent

and other costs meant a reduction in revenue to the Coliseum.

E-mail correspondence and other documents obtained during this investigation

demonstrate that DeStefano’s business relationship with Rotella and Insomniac and

Gerami and Go Ventures, went beyond his role as Assistant General Manager for the

Coliseum. E-mails obtained by numerous search warrants in this case clearly show

DeStefano was working for the interests of Rotella and Gerami while he was supposed

to be representing the interest of the Coliseum, and that he was collecting money from

the promoters for so doing. In a 2010 email, DeStefano describes a wire transfer of

Coliseum money that he instructs Gerami to wire to DeStefano’s accounts.

“Rent will only be $25,000. Ron isn’t aware =f that yet I’ve already

gotten it cleared by Pat. I was able =o change the line items that we

spoke of earlier. There will be a =60,000 wire that hits your account


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hopefully today. When it does I would =ike that immediately wired over

into my account. Kym has all of my =ank info. I’ll give you a call later after

Glo confirms the wire =as been sent out. Hopefully, you are bringing back

the tickets today =o we can get them counted and finalize this early next

week. Give me a call =ith any questions brother. I’m heading over to

LAPD for the =ebrief from New Years at 1PM.”

Bank records obtained by search warrant show that, between September 2008

and September 2010, Insomniac (Rotella) paid DeStefano and his companies

$1,175,000, and between January 2009 and April 2010, Go Ventures (Gerami) paid

DeStefano and his companies $716,680. In total, DeStefano and his companies were

paid $1,891,680 by the two promoters. None of this money was paid over to the

Coliseum.

It is my belief that Rotella and Gerami paid DeStefano not only to be allowed to

continue to hold their events at the Coliseum, but to directly lobby for them to save

millions of dollars from his inside ability to affect the contract for the events and the

amount of rent paid to the Coliseum. Lynch became aware of the relationship and

allowed it to continue. I believe one of the reasons this was done was to allow Lynch to

continue to collect hundreds of thousands of dollars in kickbacks Lynch was receiving

from Estrada.

Beginning in 2009, defendant Lynch facilitated DeStefano’s crimes by permitting

DeStefano to continue to run the events promoted by Rotella and Gerami despite

DeStefano’s personal financial interest in those same events of which Lynch was

notified. Further, defendant Lynch facilitated a scheme by DeStefano to embezzle


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$70,0000 for an exclusive marketing and sales agreement between the Coliseum and

Coca-Cola.

Lederkramer told me that he spoke to Coliseum Food and Beverage General

Manager Hugh Gallagher. Gallagher told Lederkramer he (Gallagher) had been paid a

$5,200 commission by DeStefano for a food and beverage deal with Coca-Cola.

According to Lederkramer, the Coliseum had no knowledge of such an agreement with

Coca-Cola. Lederkramer provided me with a partially executed Beverage Marketing

Agreement dated October 21, 2009, between Coca-Cola and the Los Angeles Memorial

Coliseum Association. The Los Angeles Memorial Coliseum Association is the LLC for

the Food and Beverage arm of the Coliseum. The contract was never fully executed.

Lederkramer then provided me with a fully executed Beverage Marketing Agreement

dated January 26, 2010, between Coca-Cola and the Los Angeles Memorial Coliseum

Events, LAC Events, DeStefano’s company. According to Lederkramer, the Coliseum

was not aware of this agreement and did not receive any of the proceeds from this

agreement. It appears this agreement was made between DeStefano and Coca-Cola.

This marketing agreement allowed Coca-Cola to sell product at the EDC event.

According to Lederkramer, typically, with this type of legitimate marketing agreement,

some of the funds would go to the Coliseum and the rest would go to the promoter,

Insomniac. Insomniac owner Rotella told Lederkramer he was not aware of any

marketing deal with Coca-Cola.

DeStefano signed an invoice to Coca-Cola, which was written on Los Angeles

Memorial Coliseum letterhead, referring to the “deal involving Coca-Cola Enterprises

Inc. and LAC Events Inc”. Bank records show $70,000 was paid by Coca-Cola to LACE,


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De Stefano’s company, and deposited in the LACE account in November 2010. None

of the money was paid to the Coliseum by LACE.

Lederkramer had a conversation with Tony Estrada, owner of Service for All

Events, a company that provides clean up and other services at the Coliseum. Estrada

was hired by Lynch approximately 13 years ago as a consultant. Estrada eventually

provided all the porter and maid services for the Coliseum. Estrada told Lederkramer

that when his hourly wages increased by $1.25 per employee a few years ago, it was

because Lynch demanded a $1.00 an hour per employee kick back. Estrada would

deposit the funds into a bank account out of Miami for Lynch. Following the Coliseum

Commission scandal at the beginning of the year, and Lynch’s resignation, Estrada

began giving the $1.00 an hour per employee kickback that was previously paid to

Lynch directly back to the Coliseum.

In October or November of 2009, Lederkramer presented Lynch with an analysis

of the cost of Estrada’s business. The analysis showed the Coliseum could save over

$400,000 per year by bidding and going with another company. Lynch ignored the

analysis and continued with Estrada’s company. Lynch has full power over managerial

decisions and is ultimately responsible for making the decisions. For the first few years,

Estrada had a contract for his services, but eventually was paid based only upon what

Lynch told Lederkramer to pay him. If the rate would increase, Lynch would simply tell

Lederkramer what to pay him. Estrada would bill the Coliseum accordingly.

The Coliseum Commission hired Nedy Warren, Esq., Workplace Consulting and

Investigations Company to conduct an investigation, after the EDC event that resulted in

the death of one of the concert-goers. Warren issued a report, entitled, “Privileged and


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Confidential Report of Investigation” which I have reviewed. Included in the report were

documents obtained from Estrada by Nedy Warren. Estrada provided his accounting

records showing the $1.00 overpayment along with the corresponding cancelled

checks made out to Patrick Lynch from his company, Services For All Events, Inc. The

checks were deposited into a Washington Mutual Bank/Chase Bank account in the

name of Patrick Lynch. The payments are dated from August 10, 2006 to January 20,

2011 and total $366,034.01.

Bank records obtained via search warrant were provided to Los Angeles County

District Attorney Auditor Jose Soltero to examine. Soltero is conducting a full audit of

the records. He summarized his findings in a spread sheet that he provided to me that

shows deposits from Insomniac and Go Ventures to DeStefano’s companies, LACE

and Private Events Management. Soltero indicated that bank records show payments

and wire transfers from Go Ventures Bank of America account to DeStefano’s Bank of

America accounts, between 01/30/09 and 04/16/10, totaling $716,680. The memo lines

on the payments include venue payments for Monster Massive and Love Fest, and

“venue rent.”

Soltero examined bank records that confirm the following payments by or to

defendants relating to events at the Coliseum:

• Payments to DeStefano from Insomniac and Go Ventures ($1,891,680)

• Payments to Lynch From Services for All Events ($385,500.41)

• Payments to DeStefano from American Gladiator ($50,000)

• Payments to DeStefano from Blades of Glory Dream Works ($74,000)

• Payments to DeStefano from Tool of North America ($10,290)


1 • Payments to DeStefano from Southern Wine and Spirits of America ($49,500)

2 • Payments to DeStefano from Coca-Cola ($70,000) 3

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Between February 24, 2012, and February 29, 2012 Senior Investigator D. Wolf

and I interviewed American Gladiator Company Executive Producer Glenn Stickley,

Michael Wilson, Location Scout and Manager from Tool of North America, and Michael

Pasqua Marketing Asset Manager for Coca-Cola.. The purpose of the interviews was

to gather information about the contracts and payments made by their respective

companies to DeStefano’s companies. In each case, the above-entities believed the

business transactions were being conducted with DeStefano as the representative for

the Coliseum. They were unaware that DeStefano was the owner of LACE and

believed LACE was a part of the Coliseum, which it is not. The payments were made to

LACE at the direction of DeStefano.

Bank records confirm that all payments were deposited into LACE’s bank

accounts. The $50,000 paid to LACE by American Gladiator Co. was a deposit for the

use of the Coliseum as a filming location. There is no evidence that the Coliseum was

aware of these payments, nor did the Coliseum receive any portion of the money paid to

LACE or DeStefano.

In addition, an unsigned letter of agreement, on Los Angeles Memorial Coliseum

Letterhead, dated 9/1/09 from LACE from Southern Wine and Spirits of America was

found. The agreement established that Southern Wine and Spirits purchased the rights

to the Spirit Category, which is believed to include spirit products to be sold at the

Coliseum, and advertising. Bank records confirm payment by Southern Wine and

Spirits to LACE was made. Checks were deposited into the LACE account, totalling


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$49,500, between 2/17/10 and 7/16/2010. I believe that defendant DeStefano

embezzled the amounts paid by Southern Wine and Spirits to permit sale and

advertising of their products at the Coliseum.

A document entitled, “’Blades of Glory’ LOCATION AGREEMENT period 2

between Dream Works Productions and the LA Coliseum & Sports Area, through LAC

Events Inc.” was found during the investigation. The agreement appears to correspond

to event billing from LAC Events Inc. dated August 8, 2006, payment records from

Blades of Glory Bank of America account for $74,000 to LAC Events Inc. on October 5,

2006, and bank records showing a deposit in the same amount into the LACE account.

I believe that DeStefano, through his personal company, LACE, received payment from

Dream Works Productions for the use of the Coliseum facilities for filming. I believe that

the evidence shows that DeStefano embezzled this money from the Coliseum because

it is the Coliseum that was entitled to receive the fees for use of its facilities, not

DeStefano, as a Coliseum employee.

Based on the foregoing, I believe the evidence proves that defendant DeStefano,

while being paid by the Coliseum responsible for the booking and contracting of events

at the Coliseum, was also secretly being paid by Insomniac through defendant Rotella

and Go Ventures, through defendant Gerami. The diversion and siphoning of funds, the

receipt of payments from promoters, and the embezzlement of money by DeStefano

were facilitated by defendant Lynch, who was aware of DeStefano’s dual role and

divided loyalties. Bank records clearly establish the money trail between Rotella,

Gerami and DeStefano. These records along with the computer evidence of contracts

and emails clearly show all parties were aware of and active participants of the crimes.


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I believe that the payments from defendants Rotella and Gerami to LACE and Todd

DeStefano amount to bribery and embezzlement of funds that rightfully belonged to the

Coliseum. Defendant DeStefano was paid by promoters for the use of the Coliseum at

a reduced rate, and to keep the costs “tight” despite his obligation to the Coliseum to

ensure that it received the funds to which it was entitled.

In addition, evidence proves conclusively that DeStefano was paid by several

other companies including Dream Works, American Gladiators, Southern Wine &

Spirits, and Coca-Cola for use of, advertising, right of sales and advertising at the

Coliseum facilities. The Coliseum did not receive any portion of these payments, which

were made directly to LACE by each of the companies.

I further believe the evidence proves that defendant Lynch used his position as

General Manger to personally receive kick-backs of more than $385,000 from Antonio

Estrada, whose private company was paid by the Coliseum for clean up services. Bank

records, computer evidence of a contract between Lynch and Estrada, and statements

from Estrada, clearly show both parties were aware of and active participants in these

crimes.

Based on all the evidence obtained in this case, I believe Todd DeStefano,

Patrick Lynch, Pasquale Rotella and Reza Gerami committed the crimes of

Embezzlement, Conspiracy to Commit Embezzlement, Grand Theft and Bribery when

they conspired to hide the true relationship between DeStefano, Lynch, and promoters,

and to conceal diversion of payments for filming, advertising, and sales at the Coliseum

that were paid to DeStefano and Lynch. Finally, I believe Todd DeStefano, while

employed by the Coliseum, exerted influence on contracts between the Coliseum and


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Insomniac and Go Ventures, for his personal financial benefit, which is a criminal

Conflict of Interest.

Finally, losses suffered by the victim, the Los Angeles Coliseum, are as follows:

Defendants DeStefano, Lynch & Garami

Payment by Go-Ventures to LACE & DeStefano $ 716,680.

Defendants DeStefano, Lynch & Rotella

Payment by Insomniac to LACE & DeStefano $1,175,000.

Defendant DeStefano & Lynch

Payment by Coca-cola $ 70,000.

Defendant Lynch

Payments by Service for All Events (Estrada) $ 385,500.41

Defendant DeStefano

Payments by Southern Wine and Spirits $ 49,500.

Payment by American Gladiator $ 50,000.

Payment by DreamWorks Blades of Glory $ 74,000.

TOTAL LOSS TO COLISEUM $2,520,180.41

I believe that the losses are attributable to each of the defendants are as follows:

DeStefano & Lynch $ 716,680. (joint/several with Lynch & Gerami

$1,175,000. (joint/several with Lynch & Rotella)

$ 70,000. (joint/several with Lynch)

TOTAL DeStefano & Lynch $1,961,168.00

DeStefano only $ 173,500. (solo)

TOTAL DESTEFANO $2,065,250.00


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Lynch only $ 385,500.41 (solo)

TOTAL LYNCH $2,347,180.41

TOTAL GERAMI $ 716,680 (joint/several with Lynch &

DeStefano)

TOTAL ROTELLA $1,175,000. (joint/several with Lynch &

DeStefano)

ASSETS SOUGHT TO BE FROZEN

I reviewed property records pertaining to real property purchased or leased by

DeStefano, Lynch, Rotella and Gerami along with documents obtained during the

investigation. The properties, their legal descriptions, trust deeds and other

encumbrances are summarized on the attached schedule. Similarly, search warrants

were obtained for bank records pertaining to accounts held by DeStefano, Lynch,

Rotella and Gerami. Investigators reviewed those records to identify any additional

financial accounts over which the defendants have control. Finally I conducted a search

of DMV records to identify vehicles owned or registered to the defendants. Attached is

a list of the assets thus located, including location, estimated worth, the basis of the

valuation, and date of valuation. With regard to real property, I have used the market

value based on property profiles and comparable sales. With regard to vehicles, I

utilized the Kelly Blue Book. With regard to banking accounts and financial accounts, I

listed the most recent balance available from the documents available to me.

I believe that the net worth of the assets that are subject to the petition to freeze

totals which is less than three times the value of the estimated loss

$2,520,180 x 3 = 7,560540.


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Based on my training and experience, I believe that there is a substantial danger

that the assets identified herein will be dissipated by defendants, which will severely

impair the victim’s opportunity to recover restitution as is constitutionally mandated,

should the defendants be convicted of the crimes alleged. The assets are easily

liquidated.

I therefore request that this court issue a temporary restraining order freezing

the assets identified on the attached asset schedule to protect the victim’s ability to

collect restitution and the imposition of fines as the conclusion of this case

Finally, I believe that an order prohibiting Todd DeStefano, Patrick Lynch, Pasquale

Rotella and Reza Gerami or anyone on their behalf, including but not limited to

DeStefano’s wife, Carisse DeStefano and Lynch’s wife, MaryAnn Lynch, from

transferring, or otherwise encumbering the properties subject to this court’s freeze order

until further order of this court is necessary to prevent the dissipation of assets sought to

be frozen.

I declare under penalty of perjury that the forgoing is true and correct.

Dated: March , 2012 at Los Angeles, CA

________________________________ Deren Brady

l.a. coliseum corruption -- petition, indictment and motions in the criminal case

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