What is the test for liability for fraudulent misrepresentation in the context of immigration law?

behalf. In return for their investment, defendant placed each of the victims on a path that led, with a high degree of certainty, to an order of deportation. In total, the record here reflects that the defendant employed a "scheme" whereby he made reckless promises to the victims that they could obtain legal residency without information that would justify a reasonable belief in the truth of those promisesi.e. that he acted with criminal intent. (See People v. Webb (1999) 74 Cal.App.4th 688, 694; also, compare People v. Marsh, supra, 58 Cal.2d at p.736 [no liability for theft by false pretenses if defendant's "false representations were made in the actual and reasonable belief that they were true" [italics added].)