PHO TPT ATT TAM ATT eT OFFENSE #09-03030131 DOB. __08/02/87 Dare OFanuse wo SNOOP. ARRESTING AGENCY: THE STATE OF TEXAS MAGISTRATE: COUNTY OF NUECES BOND: AEEIDAVIT/COMPLAINT BEFORE ME, the undersigned authority, on this day personally appeared__William C. Abbott __ who after being duly sworn, on oath says that he has good reasons to believe and does believe that on or about the 17th day of_April » 20,08, and before the filing of this affidavit, in Nueces County, Texas. One:_ Stephanie N. Garza DOB:, 08/02/87 did then and there commit the offense of__Injury to a Disabled Individual, PC 22.04 (SJF al as probable cause for this belief and for an arrest warrant would show the following: Ihave a Corpus Christi Police Dept. offense report #09-03030131 generated by Sgt. Greg Shipley #1748 on 3/3/09. ‘The report indicates that a cell phone was turned over to Officer Shipley and contained numerous acts of what appeared to be mental patients being assaulted at a mental health facility. The reporting party is not identified but it was reported that the phone was found at the Wholesale Mart located on Ayers St. in Corpus Christi, Nueces ‘County, Texas, On 3/6/09 I requested a laboratory examination and submitted the Samsung phone submitted into evidence by Sgt. Shipley to Sgt. Bob McFarland in Computer forensics. I have a computer media forensics report from Sgt. McFarland indicating that 13 allocated images, 20 viewable movies, and 46 images were recovered from the phone. On 3/6/09 I viewed the movie files that were provided to me from the phone, the movie files contained video recordings with audio showing mentally disabled residents engaged in physical fights that were being recorded by staff members, Several videos show staff members encouraging different individuals to engage in physical contact as the activity is recorded and at least four of the videos show this physical contact to result in bodily injury as, defined by statute in Texas Penal Code definitions. The videos date from 1/12/08 to 5/11/08 by time stamp. [havea recorded interview with Melissa Soliz and Amanda Morales on 3/7/09 identified as investigators for Adult Protective Services with TDPRS. The videos were viewed, the unit was identified by name and reported to be part of the Corpus Christi State School located at 902 Airport Rd. in Corpus Christi, Texas. From the videos the investigators were able to identify to me all the victims which were confirmed to be residents with mental disabilities and 11 State school staff members. One video resulting in bodily injury to a facility residentivictim identifies staff member Stephanie Garza as observing the residents fight causing bodily injury by omission and failing to act. Garza is also identified in another video involving the mistreatment of residents in the facility.PPE TT PT AHI TAM ATT ert Ihave a recorded statement from a State School resident identified in videos indicating that staff members in his unit encouraged them fo fight. The statement was provided and conducted by Investigators Gallegos and Richter with the Office of the Inspector General for the State of Texas on 3/9/09. havea recorded statement from a State School resident identified in videos indicating that he was injured during thea fight describing a cut to his eye. He indicated that staff members encouraged the fight. This fight was one that Garza was identified as watching, The statement was provided and conducted by Investigators Hohensee and Gutierrez with the Office of the Inspector General for the State of Texas on 3/9/09, ‘Sworn to and signed before me by_William C. Abbott on tnts tneoAiay of LAr 2009 William C. Abbott istrict Attorney jack Puleher VICTIM:PPE TT PT AHI TAM ATT ert FBINO._wa DPSNO._wa, D.O.B. __ 04/02/87 DATE OF ARRES: ARRESTING AGENCY: THE STATE OF TEXAS COUNTY OF NUECES BEFORE ME, the undersigned authority, on this day personally appeared_William C. Abbott __ who after being duly sworn, on oath says that he has good reasons to believe and does believe that on or about the 12th day of_January 20.08, and before the filing of this affidavit, in Nueces County, Texas. One:_Guadalupe Delarosa Jr. DOB: 04/02/87, did then and there commit the offense of_Injury to a Disabled Individual, PC 22.04 (3) ai as probable cause for this belief and for an arrest warrant would show the following: Ihave a Corpus Christi Police Dept. offense report #09-03030131 generated by Sgt. Greg Shipley #1748 on 3/3/09. The report indicates that a cell phone was turned over to Officer Shipley and contained numerous acts of what appeared to be mental paticuts being assaulted at a mental health facility. The reporting party is not identified but it was reported that the phone was found at the Wholesale Mart located on Ayers St. in Corpus Christi, Nueces County, Texas. ‘On 3/6/09 1 requested a laboratory examination and submitted the Samsung phone submitted into evidence by Sgt. Shipley to Sgt. Bob McFarland in Computer forensics. I have a computer media forensics report from Sgt. MeFarland indicating that 13 allocated images, 20 viewable movies, and 46 images were recovered from the phone. On 3/6/09 I viewed the movie files that were provided to me from the phone, the movie files contained video recordings with audio showing mentally disabled residents engaged in physical fights that were being recorded by staff members. Several videos show staff members encouraging different individuals to engage in physical contact as the activity is recorded and at least four of the videos show this physical contact to result in bodily injury as. defined by statute in Texas Penal Code definitions. The videos date from 1/12/08 to 5/11/08 by time stamp. Ihave a recorded interview with Melissa Soliz.and Amanda Morales on 3/7/09 identified as investigators for Adult Protective Services with TDPRS. The videos were viewed, the unit was identified by name and reported to be part of the Corpus Christi State School located at 902 Airport Rd. in Corpus Christi, Texas. From the videos the investigators were able to identify to me all the victims which were confirmed to be residents with mental disabilities and 11 State school staff members. One video resulting in bodily injury to a facility resident/vietim identifies staff member Guadalupe Delarosa as encouraging the residents to fight. Delarosa is also identified in another video filming a fight which was reported (o have been encouraged by staff members and resulted in bodily injury to 2 resident.