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comp AARON D. FORD Attorney General CHELSEA KALLAS (Bar No. 13902) 16 Deputy Attorney General Le Office of the Attorney General 555 E. Washington Ave., Ste. 3900 Las Vegas, Nevada 89101-1068 P: (702) 486-5707 F: (702) 486-0660 Ckallas@ag.nv.gov Attorneys for the State of Nevada JUSTICE COURT, LAS VEGAS TOWNSHIP CLARK COUNTY, NEVADA STATE OF NEVADA, Case No.: 19F09650ABC Plaintiff, Dept. No.: 3 v. JOHNNY ESPINOZA, JACKLYNN ESPINOZA, SAVANNA ESPINOZA, Defendants. CRIMINAL COMPLAINT AARON D. FORD, Attorney General for the State of Nevada, complains and charges that: ‘The above-named defendants, JOHNNY ESPINOZA, JACKLYNN ESPINOZA and SAVANNA ESPINOZA, have committed one or more of the following crimes: CONSPIRACY TO COMMIT BURGLARY, a gross misdemeanor in violation of NRS 205.060, 199.480; BURGLARY, a category “ felony in violation of NRS 205.060; THEFT IN THE AMOUNT OF $650 OR MORE BUT LESS THAN $3,500 WITH THE ASSISTANCE OF A CHILD, a technological crime under NRS 205A.030 and a category “C” felony in violation of NRS 205.0832, 193.162; THEFT IN THE AMOUNT OF $650 OR MORE BUT LESS THAN $3,500, a technological crime under NRS 205A.030 and a category “C” felony in violation of NRS 205.0832; THEFT IN THE AMOUNT OF $3,500 OR MORE WITH THE ASSISTANCE OF A CHILD, a technological crime under NRS 205A.030 and a category “B” felony in violation of NRS 205.0832, 193.162; CRUELTY TO ANIMALS, a category “D” felony, in violation of Page 1 of 9 Cer AH eR wD 10 ist 12 13 14 15 16 7 18 19 20 21 22 23 24 25 26 27 28 INRS 574.100(1)(a); and OWNERSHIP OR POSSESSION OF FIREARM BY PROHIBITED PERSON, a category B felony, in violation of NRS 202.360. All of the acts alleged herein have been committed or completed between November 2016, and February 2018, by the above-named defendants, within the County of Clark, State of Nevada, in the following manner: COUNT 1 CONSPIRACY TO COMMIT BURGLARY Gross Misdemeanor - NRS 205.060, 199.480 The Defendant, JOHNNY ESPINOZA, did on or about November 2016, willfully and unlawfully conspire with SAVANNA ESPINOZA, to commit a burglary, by the Defendant and SAVANNA ESPINOZA agreeing to commit the acts as set forth in Count 2, said acts being incorporated by this reference as though fully set forth herein. COUNT2 BURGLARY Category "B" Felony - NRS 205.060 ‘The Defendant, JOHNNY ESPINOZA, did on or about November 2016, willfully, unlawfully and feloniously enter a building, owned or occupied by CURTIS POPPETT, located at 9745 Grand Teton Drive, ‘Unit 2003, Las Vegas, Clark County, Nevada, with intent to commit larceny and/or a felony, to wit: thet, the Defendant(s) being criminally liable under one or more of the following principles of criminal liability, {to wit: (1) by directly committing this crime; and/or (2) by aiding or abetting in the commission of this crime, ‘with the intent that this crime be committed, by Defendant JOHNNY ESPINOZA transporting his icoconspirator(s) to said building with the intent larceny and/or theft be committed; and/or (3) pursuant to a conspiracy to commit this crime, with the intent that this crime be committed. COUNT3 THEFT IN THE AMOUNT OF $650 OR MORE BUT LESS THAN $3,500 ‘WITH THE ASSISTANCE OF A CHILD Category "C" Felony - NRS 205.0832; 205A.030; 193.162 The Defendant, JOHNNY ESPINOZA, did on or about November 2016, willfully, knowingly, feloniously, without lawful authority, with the assistance of a child, control property of another person with the intent to deprive that person of the property and/or obtain property or services of another person by a material misrepresentation with intent to deprive that person of the property or services, with the value of Page 2 of 9 Cer AH rN 10 ul 12 13 4 15 16 17 18 19 20 21 23 24 25 26 27 28 said property being $650 or more but less than $3,500, by way of acts that involved, directly or indirectly, any component, device, equipment, system or network that, alone or in conjunction with any other component, device, equipment, system or network, is designed or has the capability to (a) be programmed; or (b) generate, process, store, retrieve, convey, emit, transmit, receive, relay, record or reproduce any data, information, image, program, signal or sound in a technological format, including, without limitation, a format that involves analog, digital, electronic, electromagnetic, magnetic or optical technology, in the following manner, to wit: Defendant knowingly obtained a Husky dog named Luna from CURTIS POPPETT, with the assistance of a child, by falsely representing to CURTIS POPPETT that he would provide a home for said dog, knowing said dog would instead be sold for profit, with the value of said dog being $650 or more but less than $3,500; Defendant using the internet and/or cellular device to make said representations and/or sell said dog, the Defendant(s) being criminally liable under one or more of the following principles of criminal liability, to wit: (1) by directly committing this crime; and/or (2) by aiding or abetting in the commission of this crime, with the intent that this crime be committed, by Defendant transporting his coconspirator(s) to retrieve said dog and/or to complete sale of said dog; and/or (3) pursuant toa conspiracy to commit this crime, with the intent that this crime be committed. COUNT 4 THEFT IN THE AMOUNT OF 5650 OR MORE BUT LESS THAN $3,500 WITH THE ASSISTANCE OF A CHILD Category "C" Felony - NRS 205.0832; 205A.030; 193.162 The Defendants, JOHNNY ESPINOZA and JACKLYNN ESPINOZA, did on or about December 2016, willfully, knowingly, feloniously, without lawful authority, with the assistance of a child, control property of another person with the intent to deprive that person of the property and/or obtain property or services of another person by a material mistepresentation with intent to deprive that person of the property or services, with the value of said property being $650 or more but Jess than $3,500, by way of acts that involved, directly or indirectly, any component, device, equipment, system or network that, alone or in conjunction with any other component, device, equipment, system or network, is designed or has the capability to (a) be programmed; or (b) generate, process, store, retrieve, convey, emit, transmit, receive, relay, record or reproduce any data, information, image, program, signal or sound in a technological format, including, without limitation, a format that involves analog, digital, electronic, electromagnetic, magnetic or Page 3 of 9