Harris

BACKGROUND

I. Within One Month of Befriending Leonard, Amina

Assumes Total Control Over His Affairs In or about June 2019, when Leonard was one month shy of turning 96 years old, Amina met him at church and befriended him.3 According to Amina, on or about June 19, 2019, she became concerned that Leonard was not receiving proper care from his In-Home Supportive Services (IHSS) caregiver of more than five years, A.O.4 Amina visited Leonard at his home every day between June 23 and July 1, 2019. She asserts that at each visit, Leonard was unfed and unbathed, and his apartment was not clean. Amina purchased food and vitamins for Leonard. Based on discussions with Leonard, Amina believed A.O. was being paid for more hours than she spent caring for Leonard. Leonard’s son Michael, who lived in Germany, heard about Leonard’s new friendship with Amina on or about June 23, 2019, through discussions with A.O. Based on in-person visits and video calls, Michael believed A.O. was providing excellent care to Leonard. Michael was aware of the amounts Leonard paid A.O. for her services. Michael had been managing Leonard’s finances for the past eight-to-ten years. Michael opened a joint bank…