Memo of Points and Authorities Essay

1985 Words Mar 31st, 2013 8 Pages
Jackie Johns, Esq.
(CA Bar No. 208286)
450 Golden Gate Avenue, Rm. 10-0101
San Francisco, CA 94102-3478
(415) 436-6660
(415) 436-6683 (Fax)

Attorneys for Plaintiff the United States of America



United States of America Case No. CR-00897 Plaintiffs,


Melyssa Baylor Plaintiffs’ Memorandum of Points and Authorities in Support of Complaint for Charge of Accessory after the fact in the crime of Credit Card Fraud Defendant,


Table of Contents

Table of Authorities . . . . . . . . . . . . . . . . . . . . . . . . . . .
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Accordingly, she aided Mr. Creighton’s escape from authority as expressed by the evidence of an airline ticket on Alaska Air in the amount of $378 dated November 5, 2010 seized from her property. Melyssa Baylor can be charged as an accessory after the fact solely by lying to police and investigative officers about not having any knowledge of the engagement ring, when the evidence found in the search of her home revealed credit card statements of Terry Creighton and copies of the appraisal of the diamond engagement ring singed by Mario Battaglia.
Benjamin Creighton knowingly and with intent to defraud, used one or more counterfeit access devices during any one-year period, and by such conduct obtains anything of value aggregating $1,000 or more during that period, without the authorization of the issuer of the access device. “An Accessory is he, who is not the chief actor in the offense, nor present at its performance, but is some way concerned therein, either before or after the fact committed.” Jones’ Blackstone, Brooks 3 and 4, P. 2202; United States v. Hartwell, 26 Fed. Cas. 196, No. 15, 318; Melyssa Baylor violated this law when she assisted Benjamin Creighton after he committed a felony by aiding in his escape from conviction. The defendant, Melyssa Baylor, let Benjamin Creighton live at her house from August 15, 2010 through October 30, 2010 were

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