ELECTRONICALLY FILED

Superior Court
Case No: STK-CR-FE-2025-0005501
Date: 05/14/2025
1 RONALD J. FREITAS
District Attorney, County of San Joaquin By: Erika Hernandez
2 State Bar Number 135885
By: Cameron J Sohl, SBN 349296
3 Deputy District Attorney
222 E. Weber Avenue, First Floor, Room 101,
4 P.O. Box 990
Stockton, California 95201
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Telephone: (209) 468-2400
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Attorneys for Plaintiff
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8 SUPERIOR COURT OF THE STATE OF CALIFORNIA, COUNTY OF SAN JOAQUIN

9 STOCKTON BRANCH
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11 THE PEOPLE OF THE STATE OF CALIFORNIA, No. SO25-04224

SAN JOAQUIN COUNTY
12 Plaintiff, SHERIFF'S OFFICE CASE
DA Case: 0990018
13 vs.
Complaint No: 202505146050
14 JOSEPH THOMAS SMITH,
COMPLAINT
15 Defendant(s).

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18 I, the undersigned, say, on information and belief, that in the County of SAN JOAQUIN, State
19 of California:
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21 COUNT 1: Code Section PC 503 EMBEZZLEMENT

22 On or about May 8, 2025 in the County of San Joaquin, California, JOSEPH THOMAS OR: 05-20-25, 1:30, 8B OR 8C.

23 SMITH did commit the crime of EMBEZZLEMENT, in violation of Section 503 of the Penal
24 Code, a FELONY, who at the time and place last aforesaid, did willfully, unlawfully and
25 fraudulently take and appropriate the property of another, to-wit: FIRST TEE OF SAN
26 JOAQUIN after being entrusted with said property.
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 1 For a further and separate cause of complaint, being a different offense from but connected in

2 its commission with the charge(s) above, complainant further complains and says:

4 COUNT 2: Code Section PC 487(A) GRAND THEFT BY EMBEZZLEMENT OVER

5 $950

6 On or about May 8, 2025 in the County of San Joaquin, California, JOSEPH THOMAS

7 SMITH did commit the crime of GRAND THEFT BY EMBEZZLEMENT, in violation of

8 Section 487(a) of the Penal Code, a FELONY, who at the time and place last aforesaid did on

9 and between 03/20/23-02/13/25, falling within one year and while said defendant(s) was an

10 agent, servant, and employee of FIRST TEE OF SAN JOAQUIN, did willfully and unlawfully

11 take from said FIRST TEE OF SAN JOAQUIN money and personal property of a value

12 exceeding Nine Hundred and Fifty Dollars ($950.00), to-wit: $90,000.

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14 For a further and separate cause of complaint, being a different offense from but connected in

15 its commission with the charge(s) above, complainant further complains and says:

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17 COUNT 3: Code Section PC 470(D) FORGERY

18 On or about May 8, 2025 in the County of San Joaquin, California, JOSEPH THOMAS

19 SMITH did commit the crime of FORGERY, in violation of Section 470(d) of the Penal Code,

20 a FELONY, who at the time and place last aforesaid did, with the intent to defraud, falsely

21 make, alter, forge and counterfeit, utter, publish, pass and attempt and offer to pass, as true and

22 genuine, to-wit: ISSUED DEBIT CARD AND PERSONAL CHECKS, knowing the same to be

23 false, altered, forged and counterfeited.

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25 For a further and separate cause of complaint, being a different offense from but connected in

26 its commission with the charge(s) above, complainant further complains and says:

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 1 COUNT 4: Code Section PC 470(D) FORGERY

2 On or about May 8, 2025 in the County of San Joaquin, California, JOSEPH THOMAS

3 SMITH did commit the crime of FORGERY, in violation of Section 470(d) of the Penal Code,

4 a FELONY, who at the time and place last aforesaid did, with the intent to defraud, falsely

5 make, alter, forge and counterfeit, utter, publish, pass and attempt and offer to pass, as true and

6 genuine, to-wit: ISSUED DEBIT CARD AND PERSONAL CHECKS, knowing the same to be

7 false, altered, forged and counterfeited.

9 For a further and separate cause of complaint, being a different offense from but connected in

10 its commission with the charge(s) above, complainant further complains and says:

11

12 COUNT 5: Code Section PC 470(D) FORGERY

13 On or about May 8, 2025 in the County of San Joaquin, California, JOSEPH THOMAS

14 SMITH did commit the crime of FORGERY, in violation of Section 470(d) of the Penal Code,

15 a FELONY, who at the time and place last aforesaid did, with the intent to defraud, falsely

16 make, alter, forge and counterfeit, utter, publish, pass and attempt and offer to pass, as true and

17 genuine, to-wit: ISSUED DEBIT CARD AND PERSONAL CHECKS, knowing the same to be

18 false, altered, forged and counterfeited.

19

20 For a further and separate cause of complaint, being a different offense from but connected in

21 its commission with the charge(s) above, complainant further complains and says:

22

23 COUNT 6: Code Section PC 470(D) FORGERY

24 On or about May 8, 2025 in the County of San Joaquin, California, JOSEPH THOMAS

25 SMITH did commit the crime of FORGERY, in violation of Section 470(d) of the Penal Code,

26 a FELONY, who at the time and place last aforesaid did, with the intent to defraud, falsely

27 make, alter, forge and counterfeit, utter, publish, pass and attempt and offer to pass, as true and

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 1 genuine, to-wit: ISSUED DEBIT CARD AND PERSONAL CHECKS, knowing the same to be

2 false, altered, forged and counterfeited.

4 If the above-named defendant(s) is/are presently on probation in San Joaquin County, any

5 evidence presented at a preliminary hearing in the instant case will be used not only as a basis

6 for a holding order in this case but also as evidence of a violation of probation and, at any

7 formal hearing on that violation of probation, the People will move the transcript of the

8 preliminary hearing into evidence as a basis for the violation.

10 Pursuant to Penal Code Section 1054.5(b), the People hereby informally request that the

11 defendant and their attorney disclose to the People all information and materials described in

12 Penal Code Section 1054.3.

13

14 I declare under penalty of perjury that the foregoing is true and correct except for those things

15 stated on information and belief and those I believe to be true.

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17 Executed on May 14, 2025, at Stockton, California.

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CAMERON J SOHL
20 Deputy District Attorney
CJS/mru
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