ul 12 13 ad 16 a7 18 19 20 a1 22 23 24 25 26 ie-t049 FILED AGENCY NUMBER: WSO 19-306, CSO 198001032 and resdUlSAN 2B py 2. 03 DAL INTHE JUSTICE COURT OF RENO TORNSHTRE| =e"! HOAs - a IN AND FOR THE COUNTY OF WASHOE, STATE OF ‘NevaDA, = THE STATE OF NEVADA, Plaintife, Case No.: RCR2019-1QY4OW v Dept. No.: Z WILBER ERNESTO MARTINEZ GUZMAN, Defendant. CRIMINAL COMPLAINT CHRISTOPHER HICKS, District Attorney of the County of Washoe, State of Nevada, and MARK JACKSON, District Attorney of the County of Douglas, State of Nevada, verify and declare upon information and belief and under penalty of perjury, that WILBER ERNESTO MARTINEZ GUZMAN, the defendant above-named, has committed the crime (s) of: COUNT I. BURGLARY, a violation of NRS 205.060, a category B felony, (50424) in the mannex following, to wit: That the said defendant, WILBER ERNESTO MARTINEZ GUZMAN, on or about January 3, 2019, within the County of Washoe, State of Nevada, did willfully and unlawfully enter a barn and/or other building belonging to SHARON DAVID and/or GERALD DAVID, located at 760 La Guardia Lane, Washoe County, Nevada with the intent to commit larceny therein. w “ee10 a 12 13 14 15 16 vv 18 ag 20 21 22 23 24 28 26 COUNT IT. BURGLARY WHILE GAINING POSSESSION OF A FIREARM, a Violation of NRS 205.060, a category B felony, (50425) in the manner following, to wit: That the said defendant, WILBER ERNESTO MARTINEZ GUZMAN, on or about January 4, 2019, within the County of Washoe, State of Nevada, did willfully and unlawfully enter a trailer and/or other building belonging to SHARON DAVID and/or GERALD DAVID, located at 760 La Guardia Lane, Washoe County, Nevada with the intent to commit larceny therein, and at any time during the commission of the crime did gain possession of a firearm or deadly weapon, specifically a .22 caliber handgun. COUNT III. MURDER WITH THE USE OF A DEADLY WEAPOI violation of NRS 200.010, NRS 200.030, and NRS 193.165, a category a felony, (50001) in the manner following, to wit: That the said defendant, WILBER ERNESTO MARTINEZ GUZMAN, on or about January 9, 2019 and January 10, 2019, within the County of Douglas, State of Nevada, did willfully, unlawfully, and with malice aforethought, deliberation and premeditation, kill CONSTANCE KOONTZ, a human being, by shooting CONSTANCE KOONTZ with a .22 caliber handgun that was obtained during the commission of the burglary that occurred at 760 La Guardia Lane, Washoe County, Nevada as referenced in Count 13; AND/OR that the said defendant, WILBER ERNESTO MARTINEZ GozMAN, on or about January 9, 2019 and January 10, 2019, within the County of Douglas, State of Nevada, did willfully and unlawfully enter the home of CONSTANCE KOONTZ; located at 1439 James Road,10 aL 12 13 14 15 16 7 18 19 20 21 22 23 24 25 26 Gardnerville, Nevada, with the intent to commit larceny therein and, during the perpetration of said crime, did kill CONSTANCE KOONTZ by shooting her with a .22 caliber handgun that was obtained during the commission of the burglary that occurred at 760 La Guardia Lane, Washoe County, Nevada as referenced in Count II. COUNT IV. BURGLARY WHILE IN POSSESSION OF A FIREARM, violation of NRS 205.060, a category 8 felony, (50425) in the manner following, to wit: That the said defendant, WILBER ERNESTO MARTINEZ GUZMAN, on or about January 9, 2019 and January 10, 2019, within the County of Douglas, State of Nevada, did willfully and unlawfully enter the home of CONSTANCE KOONTZ, located at 1439 James Road, Gardnerville, Nevada, with the intent to commit larceny therein and, at any time duzing the commission of the crime did have in his possession a firearm or deadly weapon, specifically a .22 caliber handgun that was obtained during the commission of the burglary that occurred at 760 La Guardia Lane, Washoe County, Nevada as referenced in Count II. COUNT V. MURDER WITH THE USE OF A DEADLY WEAPON, a 1.0, NRS_ 200.030, and N jolation of NRS 200.1 193.165, a category A felony, (50001) in the manner following, to wit: That the said defendant, WILBER ERNESTO MARTINEZ GUZMAN, on or about January 12, 2019 and January 13, 2019, within the County of Douglas, State of Nevada, did willfully, unlawfully, and with malice aforethought, deliberation and premeditation, kill SOPHIA RENKEN, a human being, by shooting SOPHIA RENKEN with a .22 caliber handgun that was obtained during the commission of the burglary that occurred