1

Filed 10/24/23

CERTIFIED FOR PUBLICATION

IN THE COURT OF APPEAL OF THE STATE OF CALIFORNIA

FIRST APPELLATE DISTRICT

DIVISION TWO

THE PEOPLE,

Plaintiff and Respondent,

v.

JAY C. SHAH,

Defendant and Appellant;

CRAIG J. BASSETT et al.,

Claimants and Appellants.

 A162676

 (San Francisco County

Super. Ct. Nos. SCN214619,

 CT10009193)

Defendant Jay Shah’s appeal attacks the trial court’s power to levy 

property under Penal Code section 186.11, also known as the “Freeze and 

Seize” law.

1 (People v. Semaan (2007) 42 Cal.4th 79, 82 (Semaan).) The 

power is a component of California’s “aggravated white collar crime 

enhancement,” and is intended to aid in the enforcement of restitution 

awards in a subset of white collar criminal cases. (§ 186.11, subd. (a)(1); 

Semaan, at p. 86.) It does so by preventing a defendant from disposing of 

assets pending trial, and then using those assets to pay restitution to victims

if the People secure a conviction.

According to Shah, a trial court must seize any properties under section 

186.11 by the time of the sentencing hearing and no later. Any later, Shah 

1 Undesignated statutory references are to the Penal Code.
2

contends, and the trial court is divested of all jurisdiction to make orders to 

seize property under section 186.11. The court made the levying order at 

issue here eight years after Shah’s original sentencing. Shah also argues 

that this court affirmed his conviction in 2016 and did not properly remand 

the case, and so the trial court lacked jurisdiction to later levy the property.

We reject both of Shah’s arguments. Shah proposes a tortured reading 

of section 186.11 that seeks to import time limitations into the statute that 

are not there. Shah’s proposed interpretation would place restrictions on the 

trial court’s ability to make orders relating to restitution that ignore the 

legislative purpose of section 186.11 and California’s over-arching statutory 

framework for restitution in criminal cases. Within that framework, trial 

courts are empowered to make and enforce restitution orders because 

California recognizes restitution for victims of crime as a constitutional right. 

This does not change even after the Courts of Appeal decide a criminal case 

on the merits. The lack of a disposition formally remanding Shah’s original 

appeal for further proceedings was also no bar to the trial court’s levying 

order. We affirm.

BACKGROUND

A. The Criminal Case

Shah’s current appeal is the latest of several criminal and civil appeals 

in the aftermath of a jury’s September 2012 verdict against him. The charges 

and Shah’s trial were summarized in this court’s decision on Shah’s appeal 

challenging his conviction and sentence. (People v. Shah (Jul. 8, 2016,

A138475) [nonpub. opn.] (Shah).)

From September 2008 through March 2010, Shah engaged in 

fraudulent transactions involving three luxury condominiums owned by 

victim Shirley Hwang. Shah managed to transfer Hwang’s property into the 
3

name of his codefendant and then use the property to obtain over $2 million 

in loans for himself. 

Shah was convicted of multiple offenses, including conspiracy to 

commit money laundering (§ 182, subd. (a)(1)), identity theft (§ 530.5, 

subd. (a)), grand theft (§ 487, subd. (a)), money laundering (§ 186.10, 

subd. (a)), burglary (§ 459), and filing false deeds including deeds of trust 

(§ 115, subd. (a)). Enhancement allegations including taking a property 

valued over $3.2 million in the commission or attempted commission of a 

felony pursuant to former section 12022.6, subdivisions (a)(2) through (a)(4),

and special findings, including a pattern of white collar crime pursuant to 

section 186.11, subdivision (a)(2) were also found true. 

B. Pre-Conviction Section 186.11 Proceedings

Early in the criminal case, prosecutors linked Shah to at least four 

properties: a 106-acre “ranch” in Santa Clara County (the ranch property) 

and three properties in Los Banos in Merced County (the Los Banos 

properties). In mid-2010, Shah transferred the ranch property to his parents. 

In September 2010, the court ordered a temporary restraining order (TRO) 

barring “the sale, encumbrance, or disposal of the ranch and the Los Banos 

properties.” (§ 186.11, subd. (d)(2) [prosecuting agency may seek TRO to 

“prevent dissipation or secreting of assets or property”].) 

When the court entered the TRO, prosecutors recorded a lis pendens

against each of the properties.2 In October 2010, however, the court ordered 

a release of the Los Banos properties from lis pendens for the limited purpose 

of allowing Shah to withdraw up to $96,500 in equity through first or second 

2 A lis pendens is a formal notice of a pending action relating to real 

property that is recorded in the chain of title for the property. (See Code Civ. 

Proc., § 405.20.)
4

mortgages to pay for “reasonable legal fees in connection with the criminal 

proceeding, and reasonable and appropriate living expenses.” (§ 186.11,

subd. (f)(4).) 

The court replaced the TRO with a preliminary injunction in November 

2010. (§ 186.11, subd. (d)(2) [relief may include TRO, preliminary injunction, 

or “any other protective relief necessary to preserve the property or assets”].)

The preliminary injunction specifically identified Shah, as well as Shah’s 

parents and third party Craig Bassett (Shah’s former attorney), as restrained 

parties. The court ordered that the “preliminary injunction shall remain in 

effect until further order of the court.” 

As a condition of its order giving Shah access to equity in his properties 

to pay living and legal expenses, the court had ordered him to provide the 

district attorney with “an accounting of his expenditures and funds 

disbursed.” He never did. The court also provided that the People could “rerecord notices of lis pendens against the properties upon completion of the 

financing provided for in this order.” They never did.

In May 2011, Shah used third party Denise Wood separate property 

trust (Wood trust) to refinance a loan to “Megan & Kasi Properties” (which

Shah controlled as its principal), in the amount of $92,000 secured by one of 

the Los Banos properties. In June 2011, Shah also obtained a $92,000 loan 

from the “Rathkey Trust” secured by one of the Los Banos properties. 

C. Sentencing, Restitution, and Resentencing

In March 2013, Shah was sentenced to 20 years in state prison and 

ordered to pay a $14.1 million restitution fine. The parties and the court did 

not discuss the preliminary injunction at the sentencing hearing. 

The People subsequently moved to modify the sentence to include an

order for victim restitution pursuant to section 1202.4, subdivision (f). The 
5

court held a series of restitution hearings in 2015. On August 20, 2015, the 

trial court issued an order for Shah to pay $311,767.05 plus interest to 

Hwang.

In 2016, this court concluded in Shah that some of the sentencing 

enhancements were improperly imposed but affirmed the judgment in all 

other respects. (Shah, supra, A138475 [disposition as modified striking two

section 12022.6, subdivision (a)(2) enhancements and staying sentence on 

another].) It stated that Shah’s sentence shall be reduced by a total of 24 

months. 

The trial court re-sentenced Shah at a hearing on February 17, 2017. 

The court stated that it had jurisdiction and would follow the instructions of 

the appellate court. It reduced Shah’s sentence by 24 months, and ordered 

the two enhancements stricken and stayed the sentence on the third. It 

directed the clerk to prepare a new abstract of judgment. No one objected to 

conducting a resentencing hearing. Nor did anyone mention the preliminary 

injunction at this hearing.

After Shah’s resentencing, the litigants and court focused on the 

collection of the restitution owed by Shah. At a hearing on August 9, 2017, 

the prosecution served Shah with Judicial Council CR-115 form seeking

information concerning his assets. No one mentioned the preliminary 

injunction at this hearing (or the next hearing on January 11, 2018). 

At a hearing on March 26, 2018, the prosecution asked for modification 

of the earlier restitution order to account for Hwang’s attorney fees incurred 

trying to enforce the original restitution award and associated legal 

proceedings. The prosecution mentioned the frozen ranch property and Los 

Banos properties at that hearing. Again, no one suggested that the trial 

court needed to void the preliminary injunction or otherwise “unfreeze” the 
6

subject properties. During one of several continuances on its request, the 

prosecution noted: “Restitution has been pending since 2015.” On October 

29, 2020, the court issued a supplemental restitution order awarding Hwang 

an additional $704,203.79 plus interest for attorney fees. 

D. Hwang’s Civil Action

While the criminal case against Shah was proceeding, Hwang filed a 

civil action against Shah for various tort claims, including conversion, 

trespass, concealment, and slander of title. The trial court consolidated 

Hwang’s civil action with another case filed against Shah by Commonwealth 

Land Title Insurance Company (the insurer of loans Shah and his 

coconspirators had secured with Hwang’s properties). 

In September 2018, Hwang prevailed in her civil action. She secured a 

substantial civil judgment—over $3.8 million, including $1.6 million in 

punitive damages. The judgment was affirmed in the nonpublished opinion 

Commonwealth Land Title Insurance Company v. Shah (Aug. 31, 2021, 

A156674).

Hwang also prevailed on her postjudgment motion to (1) amend the 

judgment to add alter ego entities of Shah (including Megan & Kasi

Properties) as judgment debtors, and (2) void certain transfers made by the 

alter ego entities to various transferees of properties that were the subject of 

the preliminary injunction in Shah’s criminal case. The postjudgment order 

was affirmed in the nonpublished opinion Hwang v. FedEx Office & Print 

Servs. (Nov. 16, 2021, A160429) (Hwang).

In Hwang, Division Three of this court concluded that voiding the 

transfers enforced the injunction in the criminal proceedings and was 

consistent with section 186.11, subdivision (d)(2). (Hwang, supra, A160429.) 

It explained: “By voiding the transfers of the Los Banos properties, the civil 
7

court’s enforcement of the criminal injunction simply operated to maintain 

the court-ordered status quo (Shah’s possession of the Los Banos properties) 

and did not in itself establish any rights or remedies belonging to Hwang. 

Preservation of the frozen properties inured to the benefit of the public, which 

had a ‘significant’ interest both in compensating victims of white collar crime 

and in recovering fines imposed against white collar criminals. (See Pen. 

Code, § 186.11, subd. (f)(3)(E).).” (Ibid.) Division Three also confirmed that 

the criminal injunction remained in effect, and rejected the argument that 

the injunction expired back at the time of sentencing by operation of section 

186.11, subdivision (h)(1)(A) (section 186.11(h)(1)(A)). (Hwang, supra, 

A160429.) 

E. The 2020–2021 Section 186.11 Proceedings

In late 2020, against the backdrop of the two then-pending civil 

appeals, Hwang worked with the San Francisco County District Attorney’s 

Office to initiate further proceedings in the criminal case to levy the 

properties tied to Shah. Hwang filed a motion, joined by the People,3 asking 

to levy the ranch property and Los Banos properties—which they argued

remained subject to the court’s preliminary injunction—to satisfy restitution

pursuant to section 186.11. The motion also asked the court to void the 2010 

transfer of the ranch property from Shah to his parents. Meanwhile, Hwang 

obtained an order from the Merced County Superior Court permitting her to 

sell the Los Banos properties at a sheriff’s sale. 

Section 186.11, subdivision (d)(3) sets forth procedures to provide third 

parties with an opportunity to submit a verified claim of ownership as to 

seized properties. No one submitted a verified claim as to the Los Banos 

3 On a parallel track, the People filed a motion to determine the validity 

and priority of liens on the four properties. 
8

properties, but Shah’s parents and Bassett submitted verified claims for the 

ranch property. The trial court accepted Bassett’s claim (for $41,513.53). It

rejected Shah’s parent’s claim, however, upon determining that Shah had 

transferred the ranch property to them after committing the crimes alleged in 

the complaint, so they were not bona fide purchasers for purposes of section 

186.11, subdivision (e), which describes procedures for preserving status quo 

of property. 

The hearing on the motion to levy occurred over three days: December 

14, 2020, January 13, 2021, and March 17, 2021. The third party claimants 

argued at length that the trial court lacked jurisdiction to levy the four 

properties because of the passage of time since the sentencing hearing. They 

focused on the portion of section 186.11(h)(1)(A) that reads: “If the defendant 

is convicted . . . the trial judge shall continue the preliminary injunction or 

[TRO] until the date of the criminal sentencing and shall make a finding at 

that time as to what portion, if any, of the property or assets subject to the 

preliminary injunction or temporary restraining order shall be levied upon to 

pay fines and restitution to victims of the crime.” Shah’s specially appearing 

new counsel argued “levying upon property is supposed to be done at the time 

of sentencing at which Mr. Jay Shah would have been present with counsel.” 

The third parties further objected to the seizure of the Los Banos properties 

because a lis pendens had not been re-recorded against those properties. 

They also objected to an order that would unwind a transfer of property that 

occurred before the entry of the TRO and preliminary injunction. 

The trial court articulated “provisional” rulings on January 13, 2021, 

including a thorough explanation of its reasoning on section 186.11(h)(1)(A).

It noted: “I can tell you after two years in this department that a restitution 

award rarely happens at time of sentencing. And so, it seems odd that the 
9

accounting and determination of what is owed to a victim can take place over 

the course of years, but the determination under [section 186.11](h)(1)(A) of 

what money will be needed to seize to pay off restitution must happen at time 

of sentencing or the restitution hearing but not after. That would be an 

absurd result and we are to avoid absurd results.” 

The trial court then continued the hearing to allow Shah to appear with 

new counsel. On March 3, 2021, Shah’s new attorney filed a joinder to the 

third parties’ opposition to the motion. Hwang filed supplemental papers on 

March 8. The hearing concluded on March 17. 

F. The April 19, 2021 Order

The trial court issued a written order on April 19, 2021, summarizing 

its findings and granting much of the relief sought by the People and Hwang. 

The court observed that, by this time, Shah had been ordered to pay Hwang 

“in excess of $1.2 million (including interest and the costs of collection).” But

“nearly 12 years from the time her ordeal began, the total amount of 

restitution that Ms. Hwang [had] received [was] $150 that was seized from 

Shah’s prison account.” 

The trial court found it had jurisdiction to make levying orders under 

section 186.11, subdivision (h)(1)(C).4 Citing People v. Pollard (2001) 90 

Cal.App.4th 483, 489–490 (Pollard), the court noted it had personal 

jurisdiction over Shah and in rem jurisdiction over the ranch property. While 

the lis pendens had not been re-recorded against the Los Banos properties, 

the trial court decided it either had in rem or quasi-in rem jurisdiction to 

4 Section 186.11, subdivision (h)(1)(C) states: “The sentencing court 

shall retain jurisdiction to enforce the order to pay additional fines and 

restitution and, in appropriate cases, may initiate probation violation 

proceedings or contempt of court proceedings against a defendant who is 

found to have willfully failed to comply with any lawful order of the court.”
10

make orders concerning those properties. The court observed that the 

“preliminary injunction by its terms ‘shall remain in effect until further order 

of the court,’ ” and the court never terminated it. The trial court discussed 

the purposes of section 186.11 at length. After noting that Shah had already 

filed a notice of appeal, the court then referred back to its reasoning 

expressed during the January 13 hearing concerning applicability of section 

186.11(h)(1)(A). 

The court also rejected Shah and the third parties’ arguments that it 

could only levy properties at the time of sentencing. It rejected the third

parties’ proposed statutory construction and concluded that it retained the 

authority to levy the properties pursuant to section 186.11. The court also 

concluded that it had the power to address violations of the preliminary 

injunction by invalidating improper transactions. These included a lien that 

Shah’s parents had placed on the ranch property in 2013, as well as the 

transactions involving the Los Banos properties and third parties Rathkey 

trust and the Wood trust. The court also determined that the transfer of the 

ranch property to Shah’s parents prior to the entry of the preliminary 

injunction did not bar the court from levying the property. 

G. The Shah and Third Party Appeals

Two appeals followed the trial court’s April 19, 2021 order. Shah’s 

appeal No. A161990 concerned the attorney’s fee component of a 

supplemental restitution award. We granted a motion to dismiss this appeal 

as moot based on a settlement reached in Shah’s Chapter 7 bankruptcy. 

After Shah filed his notice in this appeal, Shah’s parents, Bassett, and

Rathkey trust also filed notices of appeal as third party claimants. Each of 

these third party appeals, however, has since been dismissed based on 
11

resolutions obtained in Shah’s bankruptcy proceedings. Only Shah’s appeal 

remains pending.

DISCUSSION

Two arguments remain in Shah’s appeal.

5 First, Shah argues that

section 186.11 should be construed to bar the trial court from levying a 

defendant’s property or assets at any point after sentencing. Second, Shah 

argues that the trial court lacked authority to conduct a section 

186.11(h)(1)(A) hearing four years after this court “affirmed the judgment 

and did not remand the case for further proceedings.” 

We disagree with both arguments. Section 186.11 and its legislative 

history do not support the statutory construction Shah attempts to advance, 

particularly in the overall context of California’s legislative framework for 

restitution. Victim restitution is enshrined in the California Constitution,

and California law empowers the trial courts to aid in the recovery of victim 

restitution from defendants convicted of a crime. That power extends until a 

defendant makes full restitution to his victim(s) and does not end when the 

appeal on the merits of the underlying criminal conviction is complete. There 

5 Shah raised a third argument in his opening brief that the trial 

court’s April 19, 2021 order directed that the frozen properties be levied upon 

to pay Hwang the $1,015,970.84 in restitution plus interest “nunc pro tunc”

to August 23, 2015. The People concede that an order nunc pro tunc would 

indeed have been error, but explain that the issue is now moot as a result of 

Shah’s bankruptcy proceedings. Shah admits that the issue is “possibly” 

moot, but suggests the People have not cited to documents in the record that 

“conclusively establish[ed]” mootness. Given that Shah appears to all but 

concede the issue, and provides no legal authority for his position even if not 

conceded, we decline to address it. (Department of Alcoholic Beverage Control 

v. Alcoholic Beverage Control Appeals Bd. (2002) 100 Cal.App.4th 1066, 1078 

[“Mere suggestions of error without supporting argument or authority other 

than general abstract principles do not properly present grounds for appellate 

review”].)
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was also nothing about the handling of Shah’s original appeal on the merits 

of his conviction that divested the trial court of its power to make further 

orders relating to restitution, including under section 186.11.

I. Standard of Review

Shah presents his argument on section 186.11 as a pure question of 

statutory construction requiring de novo review. We certainly agree that 

“ ‘[w]e review questions of statutory construction de novo.’ ” (Adolph v. Uber 

Technologies, Inc. (2023) 14 Cal.5th 1104, 1120.) 

Shah, however, appears to assume that a failure to strictly adhere to 

the procedure outlined in a statute whose construction was disputed 

necessarily requires automatic reversal. California law dispels that 

assumption, holding that appellate courts review questions of law (like 

statutory construction) de novo and the trial court’s application of the law for 

abuse of discretion. (E.g., Pollard, supra, 90 Cal.App.4th at p. 490; People v. 

Green (2004) 125 Cal.App.4th 360, 371 (Green) [reviewing language of section 

186.11 de novo, but reviewing actions under the doctrine of substantial 

compliance and explaining statute “ ‘may be deemed satisfied’ ” under 

doctrine by “ ‘reasonable attempt’ ” to comply “ ‘in good faith’ ”]); City of 

Sacramento v. Drew (1989) 207 Cal.App.3d 1287, 1297–1298 [pertinent 

question is whether application “is within the range of discretion conferred 

upon the trial courts under [the statute], read in light of the purposes and 

policy of the statute”].) Consistent with this framework, restitution orders 

are reviewed for abuse of discretion. (See People v. Czirban (2022) 77 

Cal.App.5th 1050, 1063–1064 [direct victim restitution orders and restitution 

as condition of probation reviewed for abuse of discretion].)

In summary, we review the legal question regarding statutory 

construction of section 186.11 de novo. But we review the trial court’s 
13

application of section 186.11 in the context of restitution for abuse of 

discretion, which may include evaluating whether a deviation from the 

procedure described by the statute was harmless under the circumstances.

II. Section 186.11 Did Not Bar the Trial Court’s April 2021 Order

A. Statutory Construction Principles

We begin with a brief overview of the California law guiding our 

statutory construction analysis. “ ‘In construing a statute, our task is to 

ascertain the intent of the Legislature so as to effectuate the purpose of the 

enactment.’ ” (Adolph v. Uber Technologies, Inc., supra, 14 Cal.5th at 

p. 1120.) “We look first to ‘the words of the statute, which are the most 

reliable indications of the Legislature’s intent.’ ” (Ibid.) “ ‘The statute’s plain 

meaning controls the court’s interpretation unless its words are ambiguous.’ ” 

(Imperial Merchant Services, Inc. v. Hunt (2009) 47 Cal.4th 381, 387–388.) 

“We decline to insert any additional restrictions into an otherwise 

unambiguous provision.” (Rudick v. State Bd. of Optometry (2019) 41 

Cal.App.5th 77, 85.) We construe the language of the statute “in its full 

statutory context, keeping in mind the nature and purposes of the statutory 

scheme as a whole.” (California Medical Assn. v. Aetna Health of California 

Inc. (2023) 14 Cal.5th 1075, 1087; Dyna-Med, Inc. v. Fair Employment & 

Housing Com. (1987) 43 Cal.3d 1379, 1386–1387.)

B. Statutory Scheme of Section 186.11

The “aggravated white collar crime enhancement” of section 186.11 

serves three functions: it creates a sentencing enhancement to charges of 

fraud or embezzlement, as well as a procedural mechanism to freeze a 

defendant’s assets and following a conviction, seize those assets to pay victim 

restitution. (Semaan, supra, 42 Cal.4th at p. 86.) We address each function

in turn.
14

1. The Enhancement

Section 186.11, subdivision (a)(1) applies to “[a]ny person who commits 

two or more related felonies, a material element of which is fraud or 

embezzlement, which involve a pattern of related felony conduct, and the 

pattern of related felony conduct involves the taking of, or results in the loss 

by another person or entity of, more than one hundred thousand dollars 

($100,000).” For purposes of the enhancement, a “ ‘pattern of related felony 

conduct’ means engaging in at least two felonies that have the same or 

similar purpose, result, principals, victims, or methods of commission, or are 

otherwise interrelated by distinguishing characteristics, and that are not 

isolated events.” (Ibid.) The enhancement adds a further consecutive prison 

term, which varies depending on the amount taken, as well as fines up to 

“double the value of the taking” in some circumstances. (Id., subds. (a)(1)–

(3), (c).) The remedies set out in section 186.11 “are cumulative to each other 

and to the remedies or penalties available under all other laws of this state.” 

(Id., subd. (k).) A fine imposed under the enhancement is “in lieu of all other 

fines that may be imposed pursuant to any other provision of law for the 

crimes for which the defendant has been convicted in the action.” (Ibid.)

2. Freezing Assets or Property

Section 186.11, subdivision (d)(2) sets out a procedure for a prosecutor

to file a petition “to prevent dissipation or secreting of assets or property” by 

freezing and seizing a defendant’s property. 

Concurrent with or subsequent to the filing of the petition, the 

prosecution may move for pendente lite orders, including a TRO or 

preliminary injunction. (§ 186.11, subd. (e)(1).) The prosecution may seek a 

TRO ex parte upon a showing of good cause. (Id., subd. (f)(1).) Once the 

court imposes the TRO or injunction, prosecutors are directed to record a lis 
15

pendens against the property pending the outcome of the criminal trial. (Id.,

subd. (d)(4).)

In anticipation of a preliminary injunction hearing, the People must 

give notice to all parties with an interest in the property, not just the 

criminal defendant. (§ 186.11, subds. (d)(3), (f)(1).) “[A]ny interested person 

may file a verified claim with the superior court stating the nature and 

amount of their claimed interest” in the assets or properties that are the 

subject of the prosecutor’s petition. (Ibid.) They may also request an “order 

to show cause hearing” and have the hearing conducted within 10 days (or 

sooner upon a showing of good cause). (Id., subd. (f)(2).)6

At the preliminary injunction hearing, the trial court will “determine 

whether the [TRO] should remain in effect, whether relief should be granted 

from any lis pendens . . . or whether any existing order should be modified in 

the interests of justice.” (§ 186.11, subd. (f)(2).) In making this determination, 

the trial court “has the discretion to consider any matter that it deems reliable 

and appropriate, including hearsay statements, in order to reach a just and 

equitable decision. The court shall weigh the relative degree of certainty of the 

outcome on the merits and the consequences to each of the parties of granting 

the interim relief. If the prosecution is likely to prevail on the merits and the 

risk of the dissipation of assets outweighs the potential harm to the defendants 

and the interested parties, the court shall grant injunctive relief. The court 

shall give significant weight to the following factors: [¶] (A) The public interest 

in preserving the property or assets pendente lite. [¶] (B) The difficulty of 

preserving the property or assets pendente lite where the underlying alleged 

6 Section 186.11, subdivision (h)(3) also requires the court “to protect 

the legitimately acquired interests of any innocent third persons” when 

issuing its final order on disposition of property to fulfill a defendant’s 

responsibility to provide restitution.
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crimes involve issues of fraud and moral turpitude. [¶] (C) The fact that the 

requested relief is being sought by a public prosecutor on behalf of alleged 

victims of white collar crimes. [¶] (D) The likelihood that substantial public 

harm has occurred where aggravated white collar crime is alleged to have been 

committed. [¶] (E) The significant public interest involved in compensating the 

victims of white collar crime and paying court-imposed restitution and fines.” 

(Id., subd. (f)(3)(A)–(E).)

3. Postconviction Seizure of Assets or Property

If the defendant is convicted, as in this case, section 186.11 directs the 

trial court to hold a hearing concerning levying the property to pay 

restitution (colloquially, the “seizing” in the “freeze and seize” process).

7 The 

timing of the commencement of the seizure process, and of the ultimate 

ruling concerning disposition of the four Shah properties to pay restitution to 

Hwang, are the primary issues raised by Shah here. 

The focal point of this appeal, section 186.11(h)(1)(A), begins: “If the 

defendant is convicted . . . the trial judge shall continue the preliminary 

injunction or [TRO] until the date of the criminal sentencing and shall make a 

finding at that time as to what portion, if any, of the property or assets subject 

to the preliminary injunction or temporary restraining order shall be levied 

upon to pay fines and restitution to victims of the crime.” (§ 186.11, 

subd. (h)(1)(A), italics added.)

7 If the defendant is instead acquitted, then the preliminary injunction 

or TRO “shall be dissolved.” (§ 186.11, subd. (g).) If the jury does not reach a 

unanimous verdict, then “the court shall have the discretion to continue or 

dissolve all or a portion of the preliminary injunction or [TRO] based upon 

the interests of justice. However, if the prosecuting agency elects not to retry 

the case, any preliminary injunction or [TRO] . . . shall be dissolved.” (Ibid.)
17

The balance of section 186.11, subdivision (h)(1) provides context 

regarding the court’s responsibilities. Subdivision (h)(1)(B) continues: 

“Additionally, the court shall order the defendant to make full restitution to 

the victim. The payment of the restitution ordered by the court pursuant to 

this section shall be made a condition of any probation granted by the court if 

the existence of facts that would make the defendant subject to the 

aggravated white collar crime enhancement . . . have been admitted or found 

to be true by the trier of fact.” The accompanying period of probation may

“continue for up to 10 years or until full restitution is made to the victim, 

whichever is earlier.” (Ibid.) Subdivision (h)(1)(C) of section 186.11 then 

provides that the sentencing court “shall retain jurisdiction to enforce the 

order to pay additional fines and restitution,” and may punish willful 

violations of the court’s orders via probation violation or contempt 

proceedings. Section 186.11, subdivision (h)(1)(D) concludes that, during any 

appeal that has the effect of staying execution of the judgment or other court 

order concerning restitution under the statute, “the preliminary injunction or 

temporary restraining order shall be maintained in full force and effect 

during the pendency of the appellate period.”

C. Analysis

As summarized above, Shah’s primary argument in this appeal is that 

section 186.11 should be construed to bar the trial court from levying the 

ranch property and Los Banos properties eight years after his original 

sentencing. Based on this proposed interpretation of the statute, Shah 

contends that the trial court’s levying order is void.

1. Plain Language of Section 186.11(h)(1)(A)

We begin with the plain language of section 186.11(h)(1)(A). Shah

commits laser focus to the provision that the sentencing court “shall” make a 
18

finding at the criminal sentencing about what portion of a defendant’s frozen 

assets it will levy to pay the defendant’s fines and victim restitution. Shah’s 

argument reads too much into the statute and, in the process, mistakes a 

procedural rule for a jurisdictional mandate. Simply put, the plain language 

of section 186.11(h)(1)(A) does not say that prosecutors lose the ability to 

ask—or that the trial court loses its discretion—to levy a frozen property by 

failing to undertake the process by the end of the sentencing hearing. 

Shah does identify a procedural misstep regarding the “freeze and 

seize” process in this case. Pursuant to section 186.11(h)(1)(A), a levying 

order should have been on the agenda at the September 2013 sentencing. It 

was not, and it appears no one brought it to the trial court’s attention. Nor 

was any issue regarding the levying order (or section 186.11 or the 

preliminary injunction) raised in Shah when Shah presented other 

arguments on sentencing.

The trial court instead held a restitution hearing on August 20, 2015. 

After the Shah decision, the trial court held a hearing on remand to adjust 

Shah’s sentence as instructed by this court. No one mentioned the 

preliminary injunction. Meanwhile, Hwang was pursuing restitution in her

parallel civil action. The People then moved forward with restitution 

proceedings in the criminal case following the remittitur from Shah. Those 

efforts culminated in the trial court’s April 19, 2021 order now before us. It is 

this order, in which the trial court found it was still permissible for it to make 

a levying order, despite the apparent earlier error in failing to issue a levying 

order at the sentencing hearing, that we now review for abuse of discretion.

(Pollard, supra, 90 Cal.App.4th at p. 490; Green, supra, 125 Cal.App.4th at 

p. 371.)
19

Despite Shah’s steadfast argument to the contrary, use of the word 

“shall” in section 186.11(h)(1)(A) is not especially helpful in connection with 

the timing of the hearing. Nothing in the plain language of the provision 

suggests that the timing of the postconviction levying order is a jurisdictional 

mandate. Nor does it contemplate the expiration of the preliminary 

injunction or TRO at the conclusion of the sentencing hearing.

8 Such

alternative language would do what Shah argues the statute does, which is 

make it impossible to levy property after sentencing. The reality, however, is 

that the statute is silent concerning what might happen if any frozen 

properties are not levied by the end of the sentencing hearing. We decline 

Shah’s suggestion to rewrite it.

2. The Integrated Lender and Green Decisions

In urging his restrictive construction of section 186.11(h)(1)(A), Shah 

relies heavily on Integrated Lender Services, Inc. v. County of Los Angeles

(2018) 22 Cal.App.5th 867 (Integrated Lender). We agree with the trial court 

that Integrated Lender is not instructive here. In that case, the defendant 

had entered a plea but did not admit the aggravated white-collar fraud 

enhancement. (Id. at p. 906.) Unsurprisingly, without an admission of guilt 

or conviction under the enhancement, section 186.11 could not be used to 

8 Indeed, the Hwang decision confirmed that the criminal injunction 

relating to the ranch property and Los Banos properties remained in effect 

after Shah’s sentencing in 2013 and at least through the date of that appeal. 

(Hwang, supra, A160429.) Citations to unpublished California appellate 

opinions are permitted when the unpublished decision “is relevant under the 

doctrines of law of the case, res judicata, or collateral estoppel,” as was true 

here. (Cal. Rules of Court, rule 8.1115(b)(1).) Shah was a party to the 

Hwang case, but none of the parties cite (let alone discuss) the decision in 

their briefing on this appeal. We therefore have no occasion to address 

whether collateral estoppel ought to bar re-litigation of the issue in 

connection with this appeal.
20

seize the subject property. (Integrated Lender, at pp. 875–876.) Integrated 

Lender made clear that even with an admission or conviction, the victim does 

not obtain a property interest based on some combination of a lis pendens, 

TRO, preliminary injunction, or restitution order under section 186.11. The 

victim must obtain a levying order under section 186.11(h)(1)(A). (Integrated 

Lender, at p. 875.) But nothing in Integrated Lender suggests that the trial

court must vacate a preliminary injunction under section 186.11 if the 

property had not been levied at the time of the sentencing hearing or that the 

court is barred from making a levying order after that hearing.

9

Nor have the parties presented any other authority that supports Shah’s 

proposed reading of section 186.11(h)(1)(A). In Green, for example, prosecutors 

never obtained a preliminary injunction while a criminal case was pending,

believing that an executed search warrant was sufficient to secure the assets 

at issue. (Green, supra, 125 Cal.App.4th at p. 365.) The appellate court 

concluded that failure to obtain a TRO or preliminary injunction to freeze the 

assets under section 186.11 barred the trial court from later exercising the 

authority to seize those assets using the procedures set out in the statute. 

(Green, at p. 370.) It expressed: “No petition, no preliminary injunction; no 

9 We note that, in dicta, the court in Integrated Lender referenced

potential difficulties in enforcement of a TRO or preliminary injunction

“years after the proceedings in which it was entered have been concluded,” 

but then declined to “reach the issue.” (Integrated Lender, supra, 22 

Cal.App.5th at p. 877.) We have no reason to question the trial court’s 

determination here that the preliminary injunction remained in effect as of 

April 19, 2021 (the date of the levying order). (See Code Civ. Proc., § 533 [“In 

any action, the court may on notice modify or dissolve an injunction or [TRO] 

upon a showing that there has been a material change in the facts upon 

which the injunction or [TRO] was granted, that the law upon which the 

injunction or [TRO] was granted has changed, or that the ends of justice 

would be served by the modification or dissolution of the injunction or 

[TRO]”].)
21

preliminary injunction, no levy.” (Ibid.) Here, unlike Green, the trial court 

issued a preliminary injunction and otherwise complied with the requirements 

of section 186.11 through Shah’s conviction. Its only arguable misstep was in 

not making a levying order at the sentencing hearing, but instead waiting until 

postconviction restitution proceedings had commenced. 

3. Statutory Context and Purpose

Our interpretation of section 186.11(h)(1)(A) is supported by the context 

of the statute as a whole. The statute is explicit that the “freeze and seize”

procedure is intended “[t]o prevent dissipation or secreting of assets or 

property.” (§ 186.11, subd. (d)(2).) The court’s duty to “order the defendant to 

make full restitution to the victim” is mandatory. (Id., subd. (h)(1)(B).) In 

deciding whether to issue a TRO or preliminary injunction, the court is 

required to give “significant weight” to factors related to the protection of the 

public interest and the victims of white collar crime. (Id., subd. (f)(3)(A)–(E).) 

It is also required to “seek to protect the interests of any innocent third 

persons.” (Id., subd. (f)(5).) 

More importantly, the statute expressly contemplates postsentencing 

proceedings by providing that the trial court “shall retain jurisdiction to 

enforce the order to pay additional fines and restitution.” (§ 186.11, 

subd. (h)(1)(C).) And notwithstanding provisions that limit the duration of 

probation conditions (like the two-year limit on felony probation set out in 

section 1203.1, subdivision (a)), the court may impose probation for “up to 10 

years or until full restitution is made to the victim.” (§ 186.11 subd. (h)(1)(B).)

Our conclusion that section 186.11 does not bar a court from issuing a 

levying order after sentencing finds further support in the legislative history of 

the statute. In 1995, the Legislature enacted Senate Bill No. 950 to 

“establish[] a procedure for the freezing and levying upon the financial assets 
22

of persons alleged to have committed aggravated white collar crime in order to 

obtain restitution for the crime victims . . . .” (Sen. Com. on Crim. Proc., 

Analysis of Senate Bill No. 950 (1995–1996) Reg. Sess.) as amended Apr. 17, 

1995, p. 3 (Senate Committee Analysis).) The office of the bill’s author felt 

“that a major point of frustration for prosecutors occurs when persons 

convicted of major fraud crimes are allowed to enjoy the benefits of their 

crimes, even after serving a term of incarceration. The author feels that it is 

very difficult to say that justice has truly been done when a person is 

sentenced to a few years in state prison but still retains millions of dollars in 

assets which should rightfully go to the victims of crime.” (Id., at p. 5.) 

The author of the bill argued that, under then-existing law, “it is very 

difficult for a prosecutor to freeze the assets of a criminal defendant pending 

a criminal conviction. As a result, by the time such a defendant is convicted, 

all assets have been dissipated, hidden, or transferred out of the jurisdiction 

of the court. The result is that major fraud defendants are sentenced to serve 

state prison sentences without losing the proceeds of their crimes. Criminals 

retain the stolen money and can enjoy a lavish life-style after release from 

custody at the expense of their victims. [¶] The victims of crime . . . are 

manipulated by sophisticated criminals. Public prosecutors do not have the 

tools necessary to get restitution for these victims whose lives, retirement or 

careers could be in a state of ruin.” (Sen. Com. Analysis, supra, at pp. 5–6.) 

In short, the key point of the “freeze and seize” law was to “freeze the assets 

of those alleged to have committed white collar crime at the time of their 

arrest. This will assure restitution is paid to victims if the defendant is 

convicted.”10 (Id. at p. 6.) 

10 The Legislature amended section 186.11 to lower the monetary 

threshold to $100,000 because it viewed the previous $500,000 level as 
23

The legislative history does not reflect any importance being placed on

the timing of a levying order with the sentencing hearing, or any limitation 

on the trial court’s jurisdiction to make a levying order only at the sentencing 

hearing. Committee records say only what legislators believed would happen 

if a defendant is convicted under the white collar criminal enhancement. 

“[T]he preliminary injunction or [TRO] would be continued until the date of 

the criminal sentencing. At the criminal sentencing, the trial judge would 

make a finding as to what portion, if any, of the assets subject to the 

preliminary injunction or [TRO] would be levied upon to pay fines, restitution 

to victims of crime, and the reasonable costs of the investigation and

prosecution of the defendant. [¶] The order . . . could exceed the total amount 

that was subject to the preliminary injunction . . . and would be converted 

into an enforceable civil judgment by the criminal court. [¶] The court would 

order that any person convicted of aggravated white collar crime to make full 

restitution to the victim or to make restitution to the victim based on his or 

her ability to pay.” (Sen. Comm. Analysis, supra, at pp. 12–13.)

Shah argues that there are “sage policy reasons” why the Legislature 

“required that the trial court make [its] findings” concerning postconviction 

levying of property at the time of sentencing “rather than going on ad 

infinitum.” Shah specifically identifies the cloud over title to a property 

caused by a lis pendens subject to a preliminary injunction, and the concern 

that an injunction lasting past the sentencing hearing could lead to 

“neglected property” and failure to pay property taxes. These rationales 

amount to speculation and find no purchase in the legislative history.

“exempt[ing] too many fraud cases to be truly effective.” (Assem. Com. on 

Public Safety, Analysis of Assembly Bill No. 2827 (1995–1996 Reg. Sess.)

Apr. 23, 1996.)
24

In summary, the legislative history of section 186.11 provides no 

support for construction of the statute that would impose the sentencing 

hearing as the absolute jurisdictional deadline for the trial court to issue a 

levying order. The Legislature was explicit that it added section 186.11 to fill 

a gap in California’s framework for victim restitution in white collar criminal 

cases, making it more difficult for someone convicted of an aggravated white 

collar crime to nevertheless benefit from their ill-gotten gains. Shah’s 

reading of the statute would contravene the stated purpose of the law by 

limiting a court’s ability to aid in recovery of restitution.

4. Broader Legislative Framework Regarding Victim Restitution

Our conclusion that the trial court was not barred from issuing a 

levying order after the sentencing hearing is also supported by California’s 

broader legislative framework for restitution. California elevates victim 

restitution to a constitutional right. Article I, section 28 of the California 

Constitution, also known as the “Victims’ Bill of Rights,” provides: “In order 

to preserve and protect a victim’s rights to justice and due process, a victim 

shall be entitled to the following rights. [¶] . . . [¶] (13) To restitution.

[¶] (A) It is the unequivocal intention of the People of the State of California 

that all persons who suffer losses as a result of criminal activity shall have 

the right to seek and secure restitution from the persons convicted of the 

crimes causing the losses they suffer. [¶] (B) Restitution shall be ordered 

from the convicted persons wrongdoer in every case, regardless of the 

sentence or disposition imposed, in which a crime victim suffers a loss. 

[¶] (C) All monetary payments, monies, and property collected from any 

person who has been ordered to make restitution shall be first applied to pay 

the amounts ordered as restitution to the victim.” (Cal. Const. art. I, 

§ 28(b)(13)(A)–(C).) 
25

Statutes like section 1202.4 implement this constitutional mandate. 

Section 1202.4, subdivision (a)(1) explains, “It is the intent of the Legislature 

that a victim of crime who incurs an economic loss as a result of the 

commission of a crime shall receive restitution directly from a defendant 

convicted of that crime.” Accordingly, the court “shall order the defendant to 

pay both” a “restitution fine” and “restitution to the victim or victims,” which 

is “enforceable as if the order were a civil judgment.” (Id., subd. (a)(3).) 

Flexibility in the use of tools available to the People and to the courts is 

central to California’s view of restitution. As the trial court recognized, 

“[R]estitution is a critical part of the criminal proceeding, and the court 

retains continuing jurisdiction to modify an order for victim restitution.” 

(§§ 1202.42, subd. (d), 1202.46; People v. Dehle (2008) 166 Cal.App.4th 1380, 

1390; People v. Turrin (2009) 176 Cal.App.4th 1200, 1207.) The key is to 

provide “full restitution” to victims of crime, regardless of the timing.

(§ 1202.4, subd. (f).) “If the amount of loss cannot be ascertained at the time 

of sentencing, the restitution order shall include a provision that the amount 

shall be determined at the direction of the court. The court shall order full 

restitution.” (Ibid.) 

Section 1202.46 further gives the court ongoing power to make orders 

relating to restitution, and explicitly avoids setting a deadline for a court to 

make an order concerning restitution. With certain exceptions not relevant 

here, section 1202.46 provides that “when the economic losses of a victim 

cannot be ascertained at the time of sentencing pursuant to subdivision (f) of 

Section 1202.4, the court shall retain jurisdiction over a person subject to a 

restitution order for purposes of imposing or modifying restitution until such 

time as the losses may be determined. This section does not prohibit a 

victim, the district attorney, or a court on its own motion from requesting 
26

correction, at any time, of a sentence when the sentence is invalid due to the 

omission of a restitution order or fine pursuant to Section 1202.4.”

Section 186.11 operates in this greater constitutional and legislative 

framework. It, “like other provisions of the Penal Code (e.g., § 1202.4 et 

seq.),” implements the California Constitution’s mandate concerning 

restitution for victims of crime. (Semaan, supra, 42 Cal.4th at p. 86.) Under

California’s other restitution laws, “there is no limitation upon when the 

court must next set a restitution hearing, nor is there a limitation on the 

permissible reasons that may prevent fixing the amount of restitution.” 

(People v. Bufford (2007) 146 Cal.App.4th 966, 971.) Given this context, and 

the central importance of restitution to California’s system of justice, we 

cannot accept Shah’s position that the sentencing hearing is the outside 

deadline for a levying order as a matter of law based on the statute as 

written.11 (Dyna-Med, Inc. v. Fair Employment & Housing Com., supra, 

43 Cal.3d at pp. 1386–1387.) 

Shah attempts to minimize the value of California’s legislative 

framework regarding victim restitution in our analysis here by arguing that 

11 Shah suggests that the timing of the restitution order in August 2015 

“begs the question why restitution was not set earlier such as at the time of 

sentencing.” He is wrong. The timing of the trial court’s first restitution 

order was entirely consistent with section 1202.4. As the trial court noted in 

its April 19, 2021 order, California’s legislative framework for restitution 

means “the court can award losses to the victim and modify that award 

should other losses accrue or be discovered. That is what happened in this 

case and what happens in many cases. It is the experience of this court that 

the determination and imposition of restitution rarely happens at [the] time 

of sentencing. It thus seems wrong that the accounting and determination of 

what is owed to a victim can take place over the course of years, [citation], 

but the determination under subdivision (h)(1)(A) of what money will be 

needed to seize to pay restitution must happen at time of sentencing and 

never after.” 
27

“[t]here are countervailing public policy considerations applicable to section 

186.11 [that] do not apply to general awards of restitution.” He attempts to 

distinguish sections 1202.4 and 1202.46 by contending they illustrate that 

the Legislature is capable of providing for continuing jurisdiction over 

matters related to restitution when it determines that to be appropriate. He 

also argues that the court can still order restitution even if it cannot levy the 

subject properties. 

We are not persuaded. As described above, section 186.11, subdivisions

(h)(1)(C) and (h)(1)(D) explicitly reserve the trial court’s “jurisdiction to 

enforce the order to pay additional fines and restitution” and mandate that 

the preliminary injunction remain in place during an appeal on the merits. 

(See also Pollard, supra, 90 Cal.App.4th at pp. 488–490.) Had the 

Legislature wished to impose such a jurisdictional bar to the trial court’s 

ability to make restitution orders that would satisfy article I, section 28 of the 

California Constitution, not to mention Penal Code sections 1202.4 and 

1202.46, it could have done so in the statutory language and the legislative 

history would reflect such efforts. It does not. As for Shah’s argument that 

the court’s inability to ever make a levying order after a sentencing hearing 

would not deny Hwang her right to restitution, his approach would still

short-circuit the purpose of section 186.11: to ease the process by preventing 

assets from being hidden, and then using those assets to actually pay 

restitution rather than to make hollow orders that are extremely difficult and 

time consuming to enforce.

In its well-reasoned April 19, 2021 order, the trial court properly 

concluded that it remained empowered to make a levying order seizing and 

disposing of the ranch property and Los Banos properties that remained 

subject to the preliminary injunction. We agree with its determination that 
28

“the better and fairer interpretation is that Ms. Hwang is entitled to have 

this court now make a finding as to ‘what portion, if any, of the property or 

assets subject to the preliminary injunction . . . shall be levied upon to pay 

fines and restitution to victims of the crime.’ ” Doing so would uphold 

Hwang’s constitutional rights while avoiding a situation in which Shah would

“achieve a windfall due to the failure of the court” to act. Such a result is 

exactly what section 186.11 and its legislative history contemplates.

Again, Shah advances an all-or-nothing jurisdictional argument. He 

offers no alternative argument that the levying order was error in excess of 

the trial court’s jurisdiction (instead of void), or that any such error was more 

than harmless. To the extent that the trial court should have made its 

findings concerning levying at the sentencing hearing, it was not raised in 

the original Shah appeal, and we are hard-pressed to identify any potential 

harm that would rise to the level of reversable error. 

II. The Remittitur from Shah’s Direct Appeal from His Conviction 

Did Not Bar the Trial Court’s April 2021 Order

Shah argues that, in Shah, supra, A138475, this court “did not remand 

the cause for further proceedings necessary to carry out the judgment.” 

According to him, the lack of a formal remand meant the trial court lacked 

any power “to make findings regarding frozen property when it failed to do so 

at sentencing when it had jurisdiction to take such action.” 

Shah is wrong. First, as noted above, section 186.11 provides that the 

trial court’s preliminary injunction “shall be maintained in full force and effect 

during the pendency of the appellate period.” (§ 186.11, subd. (h)(1)(D).) 

Section 186.11 thus anticipates hearings regarding restitution derived from 

properties frozen by a preliminary injunction under the statute. Second, 

contrary to Shah’s recollection, the trial court did in fact conduct resentencing 

proceedings to adjust the abstract of judgment to conform with this court’s 
29

disposition after the remittitur issued—it is not true that “there was nothing 

for the [trial court] to do” and something was, in fact, remanded

notwithstanding the lack of the word “remand” in this court’s disposition.

Third, Shah cites only People v. Picklesimer (2010) 48 Cal.4th 333 to support 

his position, but that case is inapposite. It concluded that a defendant seeking 

to challenge his mandatory sex offender registration status after he had 

appealed his conviction had to do so by writ of mandate in the trial court (not a 

freestanding postjudgment motion), by virtue of the rule generally precluding 

postjudgment motions in criminal cases. (Id. at p. 335.) Finally, as discussed 

above, sections 1202.4 and 1202.46 both expressly contemplate proceedings 

relating to restitution well after a conviction, and any related appeals. 

Hearings pursuant to section 186.11 are among them. 

III. Potential Further Proceedings

The Attorney General requests that the April 19, 2021 order be 

affirmed, but proposes that we remand the case for reconsideration of the 

order “in light of payment to victim Shirley Hwang and prospective payment 

to claimant Craig J. Bassett in Jay Shah’s bankruptcy proceedings.” For the 

avoidance of doubt, a party with appropriate standing may file a motion to 

reconsider in light of the bankruptcy proceedings if they wish. We lack 

sufficient information concerning the terms of orders in the bankruptcy 

proceedings to assess whether a motion for reconsideration might have merit. 

DISPOSITION

The April 19, 2021 order is affirmed.
30

_________________________

Markman, J.*

We concur:

_________________________

Stewart, P.J.

_________________________

Richman, J.

People v. Shah (A162676)

* Judge of the Alameda Superior Court, assigned by the Chief Justice 

pursuant to article VI, section 6 of the California Constitution.
31

Trial Court: San Francisco Superior Court

Trial Judge: Hon. Alexandra Gordon

Attorney for Defendant By Appointment of the Court of Appeal 

and Appellant: First District Appellate Project

Edward A. Mahler

Attorneys for Claimants Craig J. Bassett Pro Se

and Appellants: Law Offices of Craig J. Bassett

Benjamin R. Levinson

Law Offices of Benjamin R. Levinson

Mark S. Goldrosen

Law Office of Mark S. Goldrosen

Jenny D. Smith

Law Offices of Dek Ketchum

Attorneys for Plaintiff and Rob Bonta

and Respondent: Attorney General of California

Lance E. Winters

Chief Assistant Attorney General

Jeffrey M. Laurence

Senior Assistant Attorney General 

Catherine A. Rivlin

Supervising Deputy Attorney General

Allen R. Crown

Deputy Attorney General