A complaint filed by city Deputy Prosecutor Randal Lee says Manuel A. Sanchez intentionally obtained the NFL property between Nov. 1, 2002, and Aug. 6, 2003, subject to a legal agreement, but failed to make the required payments.

The complaint does not contain a specific amount of money Sanchez is said to owe the NFL.

But in a civil lawsuit filed in September, the NFL claimed Sanchez owes $457,604 for Pro Bowl tickets sold by his former company, Ticket Plus, as well as a $100,000 event sponsorship fee.

Sanchez's lawyer, Michael Green, said Sanchez, 53, has been making payments to the NFL to try to clear the debt, but has been unable to pay the full amount.

"He even sold his house to help pay the money he owes," Green said. He could not immediately say how much of the debt Sanchez has paid so far.

"He's agreed to cooperate 100 percent with everybody," Green said. "This is really a paper case, a case of guilty with an explanation," he said.

When the civil lawsuit was filed against him in September, Sanchez said he had a cash-flow problem stemming from "a considerable amount of money" owed to Ticket Plus by an un identified third party. Sanchez said a nondisclosure agreement prevented him from saying who. He said he hoped to obtain a loan to pay the NFL.

Lee said yesterday he did not believe the criminal complaint against Sanchez would affect the Pro Bowl's future in Hawai'i.

"I certainly hope not. It's a worthy thing for the players, the fans and the state's economy," Lee said.

He added that it does not matter whether Sanchez is trying or willing to pay the NFL. "He was entrusted to sell tickets for the 2003 Pro Bowl, he did so and he did not turn the money in," Lee said.

Sanchez is to be arraigned in Circuit Court on Thursday.