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District Attorney Charges Redlands High School Teacher

District Attorney Charges Redlands High School Teacher

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SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT

THE PEOPLE OF THE STATE OF CALIFORNIA, ) COURT CASE NO Plaintiff vs. Laura Elizabeth Whitehurst Defendant
) ) ) ) ) ) ) ) ) )

FELONY COMPLAINT

DA CASE NO 2013-00-0032001

The undersigned is informed and believes that: COUNT 1 On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995, a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 2 On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

Page 1
Complaint DA CASE NO: 2013-00-0032001

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 3 On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 4 On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 5

Page 2
Complaint DA CASE NO: 2013-00-0032001

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 6 On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 7 On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

Page 3
Complaint DA CASE NO: 2013-00-0032001

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 8 On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 9 On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe,DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 10

Page 4
Complaint DA CASE NO: 2013-00-0032001

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 11 On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 12 On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

Page 5
Complaint DA CASE NO: 2013-00-0032001

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 13 On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 14 On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 15

Page 6
Complaint DA CASE NO: 2013-00-0032001

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 16 On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 17 On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

Page 7
Complaint DA CASE NO: 2013-00-0032001

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 18 On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 19 On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 20

Page 8
Complaint DA CASE NO: 2013-00-0032001

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 21 On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 22 On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

Page 9
Complaint DA CASE NO: 2013-00-0032001

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 23 On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 24 On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, a DOB 08/10/1995 minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 25

Page 10
Complaint DA CASE NO: 2013-00-0032001

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 26 On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 27 On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

Page 11
Complaint DA CASE NO: 2013-00-0032001

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 28 On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 29 On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 30

Page 12
Complaint DA CASE NO: 2013-00-0032001

On or about July 1, 2012 through June 11, 2013, in the above named judicial district, the crime of UNLAWFUL SEXUAL INTERCOURSE, in violation of PENAL CODE SECTION 261.5(c), a felony, was committed by Laura Elizabeth Whitehurst, who engaged in an act of unlawful sexual intercourse with John Doe, DOB 08/10/1995 a minor, not the spouse of the defendant, the minor being more than three years younger than the defendant.

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order." ***** COUNT 31 On or about January 1, 2007 through January 31, 2007, in the above named judicial district, the crime of ORAL COPULATION OF A PERSON UNDER 18, in violation of PENAL CODE SECTION 288a(b)(1), a felony, was committed by Laura Elizabeth Whitehurst, who did unlawfully participate in an act of oral copulation with John Doe, DOB 01/26/1992, a person under the age of eighteen years.

"NOTICE: Conviction of this offense will require the court to order you to submit to a blood test for evidence of antibodies to the probable causative agent of Acquired Immune Deficiency Syndrome (AIDS). Penal Code section 1202.1."

"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code section 290. Willful failure to register is a crime."

"NOTICE: Conviction of this offense will require you to provide specimens and samples pursuant to Penal Code section 296. Willful refusal to provide the specimens and samples is a crime."

Page 13
Complaint DA CASE NO: 2013-00-0032001

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order."

"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5 limit access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the report." ***** COUNT 32 On or about September 1, 2007 through January 31, 2008, in the above named judicial district, the crime of ORAL COPULATION OF A PERSON UNDER 18, in violation of PENAL CODE SECTION 288a(b)(1), a felony, was committed by Laura Elizabeth Whitehurst, who did unlawfully participate in an act of oral copulation with John Doe, DOB 01/09/1991 a person under the age of eighteen years.

"NOTICE: Conviction of this offense will require the court to order you to submit to a blood test for evidence of antibodies to the probable causative agent of Acquired Immune Deficiency Syndrome (AIDS). Penal Code section 1202.1."

"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code section 290. Willful failure to register is a crime."

"NOTICE: Conviction of this offense will require you to provide specimens and samples pursuant to Penal Code section 296. Willful refusal to provide the specimens and samples is a crime."
Page 14
Complaint DA CASE NO: 2013-00-0032001

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order."

"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5 limit access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the report." ***** COUNT 33 On or about September 1, 2007 through January 31, 2008, in the above named judicial district, the crime of ORAL COPULATION OF A PERSON UNDER 18, in violation of PENAL CODE SECTION 288a(b)(1), a felony, was committed by Laura Elizabeth Whitehurst, who did unlawfully participate in an act of oral copulation with John Doe, DOB 01/09/1991 a person under the age of eighteen years.

"NOTICE: Conviction of this offense will require the court to order you to submit to a blood test for evidence of antibodies to the probable causative agent of Acquired Immune Deficiency Syndrome (AIDS). Penal Code section 1202.1."

"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code section 290. Willful failure to register is a crime."

Page 15
Complaint DA CASE NO: 2013-00-0032001

"NOTICE: Conviction of this offense will require you to provide specimens and samples pursuant to Penal Code section 296. Willful refusal to provide the specimens and samples is a crime."

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order."

"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5 limit access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the report." ***** COUNT 34 On or about September 1, 2007 through January 31, 2008, in the above named judicial district, the crime of ORAL COPULATION OF A PERSON UNDER 18, in violation of PENAL CODE SECTION 288a(b)(1), a felony, was committed by Laura Elizabeth Whitehurst, who did unlawfully participate in an act of oral copulation with John Doe, DOB 01/09/1991 a person under the age of eighteen years.

"NOTICE: Conviction of this offense will require the court to order you to submit to a blood test for evidence of antibodies to the probable causative agent of Acquired Immune Deficiency Syndrome (AIDS). Penal Code section 1202.1."

"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code section 290. Willful failure to register is a crime."
Page 16
Complaint DA CASE NO: 2013-00-0032001

"NOTICE: Conviction of this offense will require you to provide specimens and samples pursuant to Penal Code section 296. Willful refusal to provide the specimens and samples is a crime."

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order."

"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5 limit access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the report." ***** COUNT 35 On or about September 1, 2007 through January 31, 2008, in the above named judicial district, the crime of ORAL COPULATION OF A PERSON UNDER 18, in violation of PENAL CODE SECTION 288a(b)(1), a felony, was committed by Laura Elizabeth Whitehurst, who did unlawfully participate in an act of oral copulation with John Doe, DOB 01/09/1991 a person under the age of eighteen years.

"NOTICE: Conviction of this offense will require the court to order you to submit to a blood test for evidence of antibodies to the probable causative agent of Acquired Immune Deficiency Syndrome (AIDS). Penal Code section 1202.1."

Page 17
Complaint DA CASE NO: 2013-00-0032001

"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code section 290. Willful failure to register is a crime."

"NOTICE: Conviction of this offense will require you to provide specimens and samples pursuant to Penal Code section 296. Willful refusal to provide the specimens and samples is a crime."

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order."

"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5 limit access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the report." ***** COUNT 36 On or about September 1, 2007 through January 31, 2008, in the above named judicial district, the crime of ORAL COPULATION OF A PERSON UNDER 18, in violation of PENAL CODE SECTION 288a(b)(1), a felony, was committed by Laura Elizabeth Whitehurst, who did unlawfully participate in an act of oral copulation with John Doe, DOB 01/09/1991 a person under the age of eighteen years.

"NOTICE: Conviction of this offense will require the court to order you to submit to a blood test for evidence of antibodies to the probable causative agent of Acquired Immune Deficiency Syndrome (AIDS). Penal Code section 1202.1."

Page 18
Complaint DA CASE NO: 2013-00-0032001

"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code section 290. Willful failure to register is a crime."

"NOTICE: Conviction of this offense will require you to provide specimens and samples pursuant to Penal Code section 296. Willful refusal to provide the specimens and samples is a crime."

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order."

"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5 limit access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the report." ***** COUNT 37 On or about September 1, 2007 through January 31, 2008, in the above named judicial district, the crime of ORAL COPULATION OF A PERSON UNDER 18, in violation of PENAL CODE SECTION 288a(b)(1), a felony, was committed by Laura Elizabeth Whitehurst, who did unlawfully participate in an act of oral copulation with John Doe, DOB 01/09/1991 a person under the age of eighteen years.

"NOTICE: Conviction of this offense will require the court to order you to submit to a blood test for evidence of antibodies to the probable causative agent of Acquired Immune Deficiency Syndrome (AIDS). Penal Code section 1202.1."

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Complaint DA CASE NO: 2013-00-0032001

"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code section 290. Willful failure to register is a crime."

"NOTICE: Conviction of this offense will require you to provide specimens and samples pursuant to Penal Code section 296. Willful refusal to provide the specimens and samples is a crime."

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order."

"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5 limit access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the report." ***** COUNT 38 On or about September 1, 2007 through January 31, 2008, in the above named judicial district, the crime of ORAL COPULATION OF A PERSON UNDER 18, in violation of PENAL CODE SECTION 288a(b)(1), a felony, was committed by Laura Elizabeth Whitehurst, who did unlawfully participate in an act of oral copulation with John Doe, DOB 01/09/1991 a person under the age of eighteen years.

"NOTICE: Conviction of this offense will require the court to order you to submit to a blood test for evidence of antibodies to the probable causative agent of Acquired Immune Deficiency Syndrome (AIDS). Penal Code section 1202.1."
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Complaint DA CASE NO: 2013-00-0032001

"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code section 290. Willful failure to register is a crime."

"NOTICE: Conviction of this offense will require you to provide specimens and samples pursuant to Penal Code section 296. Willful refusal to provide the specimens and samples is a crime."

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order."

"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5 limit access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the report." ***** COUNT 39 On or about September 1, 2007 through January 31, 2008, in the above named judicial district, the crime of ORAL COPULATION OF A PERSON UNDER 18, in violation of PENAL CODE SECTION 288a(b)(1), a felony, was committed by Laura Elizabeth Whitehurst, who did unlawfully participate in an act of oral copulation with John Doe, DOB 01/09/1991 a person under the age of eighteen years.

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Complaint DA CASE NO: 2013-00-0032001

"NOTICE: Conviction of this offense will require the court to order you to submit to a blood test for evidence of antibodies to the probable causative agent of Acquired Immune Deficiency Syndrome (AIDS). Penal Code section 1202.1."

"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code section 290. Willful failure to register is a crime."

"NOTICE: Conviction of this offense will require you to provide specimens and samples pursuant to Penal Code section 296. Willful refusal to provide the specimens and samples is a crime."

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order."

"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5 limit access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the report." ***** COUNT 40 On or about September 1, 2007 through January 31, 2008, in the above named judicial district, the crime of ORAL COPULATION OF A PERSON UNDER 18, in violation of PENAL CODE SECTION 288a(b)(1), a felony, was committed by Laura Elizabeth Whitehurst, who did unlawfully participate in an act of oral copulation with John Doe, DOB 01/09/1991 a person under the age of eighteen years.
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Complaint DA CASE NO: 2013-00-0032001

"NOTICE: Conviction of this offense will require the court to order you to submit to a blood test for evidence of antibodies to the probable causative agent of Acquired Immune Deficiency Syndrome (AIDS). Penal Code section 1202.1."

"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code section 290. Willful failure to register is a crime."

"NOTICE: Conviction of this offense will require you to provide specimens and samples pursuant to Penal Code section 296. Willful refusal to provide the specimens and samples is a crime."

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order."

"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5 limit access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the report." ***** COUNT 41 On or about September 1, 2007 through January 31, 2008, in the above named judicial district, the crime of ORAL COPULATION OF A PERSON UNDER 18, in violation of PENAL CODE SECTION 288a(b)(1), a felony, was committed by Laura Elizabeth Whitehurst, who did

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Complaint DA CASE NO: 2013-00-0032001

unlawfully participate in an act of oral copulation with John Doe, DOB 01/09/1991 a person under the age of eighteen years.

"NOTICE: Conviction of this offense will require the court to order you to submit to a blood test for evidence of antibodies to the probable causative agent of Acquired Immune Deficiency Syndrome (AIDS). Penal Code section 1202.1."

"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code section 290. Willful failure to register is a crime."

"NOTICE: Conviction of this offense will require you to provide specimens and samples pursuant to Penal Code section 296. Willful refusal to provide the specimens and samples is a crime."

'NOTICE: Being charged with this criminal offense can result in mandatory pre-conviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jail or prison facility where you are incarcerated pursuant to Penal Code Section 1524.1and Health and Safety Code section 121055 following a probably cause hearing resulting in a court order."

"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5 limit access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the report." *****

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Complaint DA CASE NO: 2013-00-0032001

*

*

*

*

*

NOTICE TO DEFENDANT AND DEFENDANT’S ATTORNEY Pursuant to Penal Code Sections 1054.5.(b), the People are hereby informally requesting that defense counsel provide discovery to the People as required by Penal Code Section 1054.3. NOTICE TO ATTORNEY The materials accompanying this notice may include information about witnesses. If so, these materials are disclosed to you pursuant to Penal Code section 1054.2 which provides: "No attorney may disclose or permit to be disclosed to a defendant the address or telephone number of a victim or witness whose name is disclosed to the attorney pursuant to subdivision (a) of Section 1054.1 unless specifically permitted to do so by the court after a hearing and a showing of good cause."

I DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT AND THAT THIS COMPLAINT CONSISTS OF 41 COUNT(S). Executed at San Bernardino, California, on July 8, 2013.

Natasha Crawford Natasha Crawford DECLARANT AND COMPLAINANT

Agency: Redlands Police Department
Defendant Laura Elizabeth Whitehurst Birth Date 11/03/1984 Booking No.

Prelim Est. 00:00
CII No. A27810842 NCIC

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Complaint DA CASE NO: 2013-00-0032001

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