IND Broun vous mpurmncoe lark Count istrict Attorne Nevada daar 001305 : accel narrate Git Dy uty District Attorney JAN 11 2018 Nevada Bar #10193 200 Lewis Avenue [a Gon ate 1a Nevada 89155-2212 NANCY MALDONADO, DEPUTY Attorney ior Paintif? DISTRICT COURT CLARK COUNTY, NEVADA ‘THE STATE OF NEVADA, Plaintiff, CASENO: C-18-329127-1 =Vs- DEPTNO: XXII JEFFREY GRASSO, Defendant. INDICTMENT STATE OF NEVADA COUNTY OF CLARK The Defendant above named, JEFFREY GRASSO, accused by the Clark County Grand Jury of the crime(s) of EXPLOITATION OF A VULNERABLE PERSON (Category B Felony - NRS 200.5092, 200.5099 - NOC 55984), THEFT (Category B Felony - NRS 205.0832, 205.0835.4 - NOC 55991), THEFT (Category C Felony - NRS 205.0832, 205.0835.3 - NOC 55989), FORGERY (Category D Felony - NRS 205.090 - NOC 50461) BURGLARY (Category B Felony - NRS 205.060 - NOC 50424), OFFERING FALSE INSTRUMENT FOR FILING OR RECORD (Category C Felony - NRS 239.330 - NOC 52399), committed at and within the County of Clark, State of Nevada, on or between January 2, 2014 to February 16, 2016, as follows: COUNT 1 - EXPLOITATION OF A VULNERABLE PERSON did on or between January 2, 2014 to January 21, 2015 willfully, unlawfully and feloniously exploit a vulnerable person, to wit: GIULIAN GRASSO, who is wheelchair ‘bound ‘weorrgermaipansmara 0-0 doesSow ra nuneene 12 13 14 15 16 17 18 20 21 23 24 25 26 27 28 and suffers from traumatic brain injury, by defendant, having the trust or confidence of GIULIAN GRASSO or by use of a power of attorney or guardianship, obtain control, through deception, intimidation or undue influence, over GIULIAN GRASSO'S money, assets or property and/or by converting GIULIAN GRASSO'S money, assets or property, defendant intending to permanently deprive GIULIAN GRASSO of the ownership, use, benefit or possession of his money, assets or property having a value of more than $650.00, by taking money that was donated to GIULIAN GRASSO for his medical needs and related costs, through deception and/or conversion by withdrawing money totaling $1,491.00 by submitting forged invoices alleged to be from the Hyperbaric Institute of Nevada representing that GIULIAN GRASSO received four (4) hyperbaric treatments costing $1,491.00 and withdrawing $1,491.00 -from the GIULIANS CHOICE FOUNDATION account at Boulder Dam Credit Union ending in [when the account was supposed to reimburse for actual expenses. COUNT 2 - THEFT did on or between January 2, 2014 to January 21, 2015 willfully, knowingly, feloniously, and without lawful authority, obtain personal property, having a value of $650.00 or more, belonging to GIULIAN GRASSO, by a material misrepresentation with intent to deprive that person of the property, in the following manner, to wit: by submitting forged invoices alleged to be from the Hyperbaric Institute of Nevada representing that GIULIAN GRASSO received four (4) hyperbaric treatments costing $1,491.00 and withdrawing $1,491.00 from Boulder Dam Credit Union Account ending in itled GIULIANS CHOICE FOUNDATION, when the account was supposed to reimburse for actual expenses. COUNT 3 - BURGLARY did on or about January 6, 2014 willfully, unlawfully, and feloniously enter, with intent to commit a felony, to wit: Theft and/or Forgery, that certain building occupied by BOULDER DAM CREDIT UNION, located at 530 Avenue G, Boulder City, Clark County, Nevada. u aCOUNT 4 - FORGERY did on or about January 6, 2014 then and there willfully, unlawfully, and feloniously, with the intent to damage or defraud, falsely make, alter, forge or counterfeit invoice alleged to be from the HYPERBARIC INSTITUTE OF NEVADA, which falsely claimed service was rendered to GIULIAN GRASSO on Jamiary 2, 2014 for $498.50, COUNT 5 - BURGLARY did on or about January 28, 2014 willfully, unlawfully, and feloniously enter, with intent to commit a felony, to wit: Theft and/or Forgery, that certain building occupied by BOULDER DAM CREDIT UNION, located at 530 Avenue G, Boulder City, Clark County, Nevada, COUNT 6 - FORGERY did on or about January 28, 2014 thenvand there willfully, unlawfully, and feloniously, with the intent to damage or defraud, falsely make, alter, forge or counterfeit invoice alleged to be from the HYPERBARIC INSTITUTE OF NEVADA, which falsely claimed service was rendered to GIULIAN GRASSO on January 20, 2014 for $498.00. COUNT 7 - BURGLARY did on or about March 10, 2014 willfully, unlawfully, and feloniously enter, with intent to commit a felony, to wit: Theft and/or Forgery, that certain building occupied by BOULDER DAM CREDIT UNION, located at 530 Avenue G, Boulder City, Clark County, Nevada. COUNT 8 - FORGERY did on or about March 10, 2014 then and there willfully, unlawfully, and feloniously, with the intent to damage or defraud, falsely make, alter, forge or counterfeit invoice alleged to be from the HYPERBARIC INSTITUTE OF NEVADA, which falsely claimed service was rendered to GIULIAN GRASSO on February 25, 2014 for $165.00. COUNT 9 - BURGLARY id on or about July 8, 2014 willfully, unlawfully, and feloniously enter, with intent to commit a felony, to wit: Theft and/or Forgery, that certain building occupied by BOULDER DAM CREDIT UNION, located at 530 Avenue G, Boulder City, Clark County, Nevada,COUNT 10 - FORGERY did on or about July 8, 2014 then and there willfully, unlawfully, and feloniously, with the intent to damage or defraud, falsely make, alter, forge or counterfeit invoice alleged to be from the HYPERBARIC INSTITUTE OF NEVADA, which falsely claimed service was rendered to GIULIAN GRASSO on July 7, 2014 for $330.00. COUNT 11 - EXPLOITATION OF A VULNERABLE PERSON did on or between April 26, 2016 to May 25, 2016 willfully, unlawfully and feloniously exploit an vulnerable person, to wit: GIULIAN GRASSO, who is wheelchair bound and suffers from traumatic brain injury, by defendant, having the trust or confidence of GIULIAN GRASSO or by use of a power of attorney or guardianship, obtain control, through deception, intimidation or undue influence, over GIULIAN GRASSO'S money, assets or property and/or by converting GIULIAN GRASSO'S money, assets or property, defendant intending to permanently deprive GIULIAN GRASSO of the ownership, use, benefit or possession of his money, assets or property having a value of more than $5,000.00, by submitting a forged letter from the Hyperbaric Institute of Nevada representing GIULIAN GRASSO received 23 hyperbaric treatments costing $8,745.00 to the court for reimbursement from a fund established from the proceeds of a lawsuit for GIULIAN GRASSO, for expenses paid, when the true expenses had already been reimbursed by withdrawals from Boulder Dam Credit Union Account ending inf{titied GIULIANS CHOICE FOUNDATION. COUNT 12 - THEFT did on or between April 26, 2016 to May 25, 2016 willfully, knowingly, feloniously, and without lawful authority, obtain personal property, having a value of $3,500.00 or more, belonging to GIULIAN GRASSO, by a material misrepresentation with intent to deprive that person of the property, in the following manner, to wit: by submitting a forged letter from the Hyperbaric Institute of Nevada representing GIULIAN GRASSO received 23 hyperbaric treatments costing $8,745.00 to the court for reimbursement from a fund established from the proceeds of a lawsuit for GIULIAN GRASSO with the proceeds of a lawsuit, for expenses“ Scwwx2an een 12 13 15 16 17 19 20 21 23 24 paid, when the true expenses had already been reimbursed by withdrawals from Boulder Dam Credit Union Account ending in titled GIULIANS CHOICE FOUNDATION. COUNT 13 - OFFERING FALSE INSTRUMENT FOR FILING OR RECORD did on or about February 16, 2016 willfully, unlawfully, knowingly and feloniously, procure or offer a false or forged instrument to be filed, registered or recorded at CLARK COUNTY DISTRICT COURT, FAMILY DIVISION, to wit: by filing a PETITION TO APPOINT GUARDIAN OF PERSON AND ESTATE OF ADULT WARD, ALLOCATE FUNDS FOR SUPPORT OF WARD AND TO INVEST PROPERTY OF WARD through use of Mark C, Hafer, Esq. as his attorney, by supplying and attaching a forged letter purported to be authored by Jon Dembo of the Hyperbaric Institute of Nevada claiming that GIULIAN GRASSO received 23 hyperbaric treatments costing $8,745.00, when in truth the actual number of hyperbaric treatments was 19 costing $3,135.00, said instrument, if genuine, might be filed, registered or recorded in a public office under any law of the State of Nevada or of the United States. COUNT 14 - FORGERY did on or about February 16, 2016 then and there willfully, unlawfully, and feloniously, with the intent to damage or defraud, falsely make, alter, forge or counterfeit a letter alleged to be from Jon Dembo of the HYPERBARIC INSTITUTE OF NEVADA, which falsely claimed that GIULIAN GRASSO received 23 hyperbaric treatments at a total cost of $38,745.00. . DATED this_-___ day of January, 2018. STEVEN B. WOLFSON Clark County District Attorney Nevada Bar #001565 BY Chief Deputy District Attorne, Nevada Bar #10193 ‘ ‘woornsermasan racine ssn D0‘Names of Witnesses and testifying before the Grand Jury: DEMBO, JON - C/O CCDA, 200 LEWIS AVE, LV NV FENTON, LYNEL ~ BOULDER DAM CREDIT UNION EMPLOYEE, GRASSO, GIULIAN - C/O CCDA, 200 LEWIS AVE, LV NV GRASSO, LADONNA ~ C/O CCDA, 200 LEWIS AVE, LV NV HAFER, MARK - GUARDIANSHIP ATTORNEY FOR GIULIAN GRASSO LELLES, CAROL - WELLS FARGO ROCKWELL, GLEN - HPD ‘Additional Witnesses known to the District Attorney at time of filing the Indictment: 17BGJ041X/cl-G) wsrnannmreanaaie. 1 DOCK