https://www2.dre.ca.gov/hearingfiles/H43241LA_260325_P.pdf
P STEVE CHU, Attorney (SBN 238155) Department of Real Estate N 320 West 4th Street, Suite 350 Los Angeles, California 90013-1105 w Telephone: (213) 559-5953 Fax: (213) 576-6917 un BEFORE THE DEPARTMENT OF REAL ESTATE 10 11 12 In the Matter of the Accusation of 13 TED LEE SAWYER JR, 14 15 Respondent. STATE OF CALIFORNIA * * * No. H-43241 LA FIRST AMENDED ACCUSATION 16 This First Amended Accusation amends the Accusation filed on 17 February 12, 2026. The Complainant, Ray Dagnino, a Supervising Special Investigator of the 18 State of California, for cause of Accusation against TED LEE SAWYER JR, 19 a.k.a. THEODORE LEE SAWYER ("Respondent"), is informed and alleges as follows: 20 1 . 21 The Complainant, Ray Dagnino, acting in his official capacity as a Supervising 22 Special Investigator of the State of California, makes this Accusation against TED LEE 23 SAWYER JR. 24 2. 25 Respondent presently has license rights under the Real Estate Law, Part 1 of 26 Division 4 of the California Business and Professions Code ("Code"), as a real estate 27 salesperson. First Amended Accusation of TED LEE SAWYER JR - 1 - FIRST CAUSE OF ACTION (CRIMINAL CONVICTIONS) w 3. In aggravation, on or about May 12, 1992, Respondent pled nolo contendere and 5 was convicted in the Superior Court of California, County of Los Angeles, Case 6 No. 92V01589, for violation of California Vehicle Code section 23152(a) (Driving under the Influence), a misdemeanor. Respondent was placed on 60 months of summary probation, and 8 ordered to serve 30 days in jail and pay fines and fees. Additionally, Respondent was ordered 9 to participate in an 18 month program of treatment or counseling. 10 11 In aggravation, on or about April 19, 2018, Respondent pled guilty and was 12 convicted in the Superior Court of California, County of Orange, Case No. 17HM10131 MA, 13 for violation of California Penal Code section 21310 (Carry Dirk or Dagger), a misdemeanor, 14 and Vehicle Code section 21200.5 (Riding Bicycle under Influence of Alcohol or Drugs), a 15 misdemeanor. Respondent was placed on two years of informal probation, and ordered to pay 16 fines and fees. Additionally, Respondent was ordered to complete 60 hours of community 17 service. 18 5. 19 In aggravation, on or about April 19, 2018, Respondent pled guilty and was 20 convicted in the Superior Court of California, County of Orange, Case No. 18HM04895 M A, 21 for violation of California Penal Code section 647(f) (Public Intoxication), a misdemeanor. 22 Respondent was ordered to serve one day in jail and pay fines and fees. 23 111 24 25 26 27 First Amended Accusation of TED LEE SAWYER JR - 2 - 6. N In aggravation, on or about August 24, 2022, Respondent pled guilty and was w convicted in the Superior Court of California, County of Orange, Case No. 20HM04694 M A, for violation of California Penal Code section 594(a)/(b)(1) (Vandalism Damage $400 or un More), a misdemeanor, and Penal Code section 415(1) (Disturbing the Peace), a misdemeanor. 6 Respondent was placed on one year of informal probation, and ordered to pay restitution, fines 7 and fees. 7 . On or about June 28, 2023, Respondent pled nolo contendere and was convicted 10 in the Justice Court, Clark County, State of Nevada, Case No. 23-CR-026029, for violation of 11 Nevada Revised Statutes sections 200.481, 200.485, and 33.018 (Domestic Battery with Use of 12 a Deadly Weapon), a misdemeanor, and Nevada Revised Statutes section 200.471 (Assault), a 13 misdemeanor. Respondent was ordered to serve 12 months suspended in jail with 10 days 14 actually imposed, and pay fines and fees. Additionally, Respondent was ordered to complete 15 domestic violence counseling and community service. 16 8. 17 The convictions described in Paragraph 7 bear a substantial relationship under 18 section 2910, Title 10, Chapter 6, California Code of Regulations to the qualifications, 19 functions or duties of a real estate licensee. 20 9 . 21 The crimes of which Respondent was convicted, as described in Paragraph 7 22 above, constitute cause under sections 490 and 10177(b)(1) of the Code for the suspension or 23 revocation of all the licenses, license endorsements, and license rights of Respondent under the 24 Real Estate Law. 25 111 26 27 First Amended Accusation of TED LEE SAWYER JR - 3 - SECOND CAUSE OF ACTION N (FAILURE TO REPORT CONVICTIONS) w 10. Pursuant to Code section 10186.2, a licensee shall report, in writing, "the us conviction of the licensee, including any verdict of guilty, or plea of guilty or no contest, of any felony or misdemeanor" to the Department of Real Estate ("Department") within 30 days of the conviction. Respondent failed to report in writing to the Department the convictions described in Paragraph 3 above, within thirty (30) days of the conviction date (July 28, 2023). 9 Respondent's failure to timely report the convictions constitutes cause under section 10186.2 of 10 the Code for the suspension or revocation of the licenses, license endorsements, and license 11 rights of Respondent under the Real Estate Law. 12 11. 13 Code section 10106 provides, in pertinent part, that in any order issued in 14 resolution of a disciplinary proceeding before the Department of Real Estate, the Commissioner 15 may request the administrative law judge to direct a licensee found to have committed a 16 violation of this part to pay a sum not to exceed the reasonable costs of the investigation and 17 enforcement of the case. 18 19 20 21 22 23 24 25 26 27 First Amended Accusation of TED LEE SAWYER JR -4 - 5 10 15 20 25 WHEREFORE, Complainant prays that a hearing be conducted on the 2 allegations of this Accusation and that upon proof thereof, a decision be rendered imposing 3 disciplinary action against all the licenses, license endorsements, and license rights of 4 Respondent TED LEE SAWYER JR under the Real Estate Law, for the cost of investigation and enforcement as permitted by law, and for such other and further relief as may be proper 6 under other applicable provisions of law. J 8 Dated at Los Angeles, California 9 this 20th _day of March 20 26 11 Ray Dagnino 12 Supervising Special Investigator 13 14 cc: TED LEE SAWYER JR Ray Dagnino Sacto. 16 17 18 19 21 22 23 24 26 27 First Amended Accusation of TED LEE SAWYER JR - 5 -
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