s won ao 10 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 TORI VERBER SALAZAR FILED SUPERIOR COURT-LODI District Attorney San Joaquin County State Bar No. 213636 By: Kathy A. Murray Deputy District Attorney 222 EB. Weber Avenue Stockton, CA 95202 209.468.2400; Fax 209.465.0371 Attorneys for Plaintiff SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN JOAQUIN Lodi Branch — oo-ce-rs-2022- (GIR The People of the State of California, No. LP22-01096 LED CASE Plaintife, DA Case: CR~2022-4265385 v COMPLAINT cASA CECILIA ROSE SILVA Defendant(s). I, the undersigned, say, on information and belief, that in the County of SAN JOAQUIN, State of California: COUNT 1: VOLUNTARY MANSLAUGHTER PC.192 (A) On or about February 19, 2022, in the County of San Joaquin, California, CECILIA ROSE SILVA, did commit the crime of VOLUNTARY MANSLAUGHTER, in violation of Section 192(a) of the Penal Code, a FELONY, who at the time and place last aforesaid, did willfully,aa Ue wDn 10 1 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 unlawfully, and without malice kill, JANE Z. DOE (09/10/2007), a human being, upon a sudden quarrel and heat of passion. It is further alleged that the above offense is a serious FELONY within the meaning of Penal Code Section 1192.7(c) (Ll. RULE OF COURT 4.421(A) (3) AND PENAL CODE 1170(B) ROC. 4.421 (a) (3) /1170 (b) NOTICE: It is further alleged that said defendant, CECILIA ROSE SILVA, committed the above offense upon a victim that was particularly vulnerable, as set forth in Rule of Court 4.421(a) (3) and Penal Code section 1170(b) RULE OF COURT 4.421(A) (5) AND PENAL CODE 1170(B) ROC. 4,421 (a) (5) /1170 (b) NOTICE: It is further alleged that said defendant, CECILIA ROSE SILVA, induced a minor to commit or assist in the commission of the above offense as set forth in Rule of Court 4.421(a) (5) and Penal Code section 1170(b). For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says:10 coy 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 COUNT 2: CHILD ABUSE/ENDANGERMENT PC.273A(A) On or about February 19, 2022, in the County of San Joaquin, California, CECILIA ROSE SILVA, did commit the crime of CHILD ABUSE/ENDANGERMENT, in violation of Section 273a(a) of the Penal Code, a FELONY, who at the time and place last aforesaid, did willfully and unlawfully, under circumstances likely to produce great bodily harm and death, injure, cause, and permit a child, JANE Z. DOE (DOB: 09/10/2007), to suffer and to be inflicted with unjustifiable physical pain and mental suffering, and having the care and custody of said child, injure, cause and permit the person and health of said child to be injured and did willfully cause and permit said child to be placed in such situation that his/her person and health was endangered. RULE OF COURT 4,421(A) (3) AND PENAL CODE 1170(B) ROC. 4.421 (a) (3) /1170 (b) NOTICE: It is further alleged that said defendant, CECILIA ROSE SILVA, committed the above offense upon a victim that was particularly vulnerable, as set forth in Rule of Court 4.421(a) (3) ‘and Penal Code section 1170(b). “ “sw ne oe aa ow 10 Ww 12 13 14 15 16 17 18 1g 20 2i 22 23 24 25 26 27 28 RULE OF COURT 4.421(A) (5) AND PENAL CODE 1170(B) ROC. 4,421 (a) (5) /1170 (b) NOTICE: It is further alleged that said defendant, CECILIA ROSE SILVA, induced a minor to commit or assist in the commission of the above offense as set forth in Rule of Court 4.421(a) (5) and Penal Code section 1170(b). INFLICTION OF GREAT BODILY INJURY PC.12022.7(A) It is further alleged that in the commission of the above offense the said defendant(s), CECILIA ROSE SILVA , personally inflicted great bodily injury upon JANE %. DOE (09/10/2007), , not an accomplice to the above offense, within the meaning of Penal Code Section 12022.7 and also causing the above offense to be a serious felony within the meaning of Penal Code Section 1192.7(c) (8). For a further and separate cause of complaint, being a different offense from but connected in its commission with the charge(s) above, complainant further complains and says: COUNT 3: TRANSPORT/SELL NARCOTIC CONTROLLED SUBSTANCE HS. 11352 (A) On or about February 19, 2022, in the County of San Joaquin, California, CECILIA ROSE SILVA, did commit the crime of SALE OR TRANSPORTATION OF A CONTROLLED SUBSTANCE, in violation of Section 11352(a) of the Health and Safety Code, a FELONY, who at the timeaes one S © @ 4 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 and place last aforesaid did willfully and unlawfully transport, import into the State of California, sell, furnish, administer, and give away, and offer to transport, import into the State of California, sell, furnish, administer, and give away, and attempt to import into the State of California and transport a controlled substance, to-wit: FENTANYL. INELICTION OF GREAT BODILY INJURY PC.12022.7(A) It is further alleged that in the commission of the above offense the said defendant(s), CECILIA ROSE SILVA , personally inflicted great bodily injury upon JANE Z. DOE (DOB:09/10/2007) , not an accomplice to the above offense, within the meaning of Penal Code Section 12022.7 and also causing the above offense to be a serious felony within the meaning of Penal Code Section 1192.7(c) (8). If the above-named defendant(s) is/are presently on probation in San Joaquin County, any evidence presented at a preliminary hearing in the instant case will be used not only as a basis for a holding order in this case but also as evidence of a violation of probation and, at any formal hearing on that violation of probation, the People will move the transcript of the preliminary hearing into evidence as a basis for the violation.we eoraon ee one 10 1 12 13 14 15 16 a 18 19 20 aL 22 23 24 25 26 27 28 Pursuant to Penal Code Section 1054.5(b), the People hereby informally request that the defendant and his/her attorney disclose to the People all information and materials described in Penal Code Section 1054.3. I declare under penalty of perjury that the foregoing is true and correct except for those things stated on information and belief and those I believe to be true. Executed on 2/23/2022, at Stockton, California, em