a

Defendant: JOHNNY JOE AV '

1692114-l
JN #:
STATE'S COPY

FILED

Address: 3421 GATEWAY DR, SAN ANTONIO, TX 78210-4459

o'cLocK_
NOv 0 3

Complainants: Natalie Chavez and Rosemary Perez

Offense Code/Charge: 090141 - CAPITAL MURDER

2016

DONNA KAY M9KINNEY

MULTIPLE

DISTRICT CLERK
cou
, TEXAS

PERSONS
PH Court: 437
GJ: 612594
SID #:829184
JN #: 1692114-1
Witness: State's Attorney

court *1437
Cause #:

?n 1 6-, OR 'l

n17

tN THE NAME AND BY AUTHORITY OF THE STATE OF TEXAS, the Grand Jury of Bexar County, State of

Texas, duly organized, empanelled and sworn as such at theJcptrgber term, 4.D., 2016, of the

2%0

Judicial District Court of said County, in said Court, at said term, do present in and to said Court that in the
County and State aforesaid, and anterior to the presentment of this indictment:
COUNT 1
Paragraph A
on or about the 18th Day of December, 2014, JOHNNY JOE AVALOS, hereinafter referred to as defendant, did
intentionally and knowingly cause the death of an individual, namely, Natalie Chavez, by asphyxiating Natalie
Chavez with the hand and arm of the defendant, by asphyxiating Natalie Chavez with a plastic bag, and'by a
manner and means unknown to the Grand Jury, and on or about the 1Oth day of January,2015, did intentionally
and knowingly cause the death of another individual, namely, Rosemary Perez, by asphyxiating Rosemary
Perezwith the hand and arm of the defendant, and by a manner and means unknown to the Grand Jury, and
both murders were committed pursuant to the same scheme or course of conduct, but during different criminal
transactions;
Paragraph B

on or about the 18th Day of December, 2014, JOHNNY JOE AVALOS, hereinafter referred to as defendant, did
intentionally cause the death of an individual, namely, Natalie Chavez, by asphyxigtlng Natalie Chavez with the
hand and arm of the defendant, by asphyxiating Natalie Chavez with a plast'tpagi, and by a manner and means
unknown to the Grand Jury, and the defendant was in the course of committing or attempting to commit the
offense of AGGRAVATED SEXUAL ASSAULT OF Natalie Chavez;
AGAINST THE PEACE AND DIGNITY OF THE STATE.
Foreman of the Grand Jury

Defendant: JOHNNY JOE AV ,

1695737-l
JN#:
STATE'S COPY

FILED

Address: 3421 GATEWAY DR, SAN ANTONIO, TX 78210-4459

o'cLocK_

Complainant: CELIA ANN LOPEZ AND GENEVIEVE RAMIREZ

NOv 2

I 2016

DONNA KAY M9KINNEY

CoDefendants:

DISTRICT CLERK

Offense Code/Charge: 090141 - CAPITAL MURDER-MULTIPLE

PERSONS
DEPUTY

GJ: 613804
Court #: 437

PH Court: 437

MAG NO:

SID #:829184

Cause #:

,0

63

TRUE BILL OF INDICTMENT

N THE NAME AND BY AUTHORITY OF THE STATE OF TEXAS, the Grand Jury of Bexar County, State of

Texas, duly organized, empanelled and sworn as such at the November term, 4.D., 2016, of

the VIT

Judicial District Court of said County, in said Court, at said term, do present in and to said Court that in the
County and State aforesaid, and anterior to the presentment of this indictment:
on or about the 15th Day of April, 2015, JOHNNY JOE AVALOS, hereinafter referred to as defendant, did
intentionally and knowingly cause the death of an individual, namely, Celia Ann Lopez, by asphyxiating Celia
Ann Lopez with the hand and arm of the defendant, by asphyxiating Celia Ann Lopez with a plastic bag, and by
a manner and means unknown to the Grand Jury, and on or about the 3rd day of April, 2015, did inteniionally
and knowingly cause the death of another individual, namely, Genevieve Ramirez, by asphyxiating Genevieve
Ramirez with the hand and arm of the defendant, and by a manner and means unknwn'toihe Gnd Jury, and
both murders were committed pursuant to the same scheme or course of conduct, but during different criminal
transactions;

AGAINST THE PEACE AND DIGNIry OF THE STATE

Foreman of the Grand Jury