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SUPERIOR COURT OF CALifORNIA

County of Riverside
AFFIANT'S

DECJ..ARATION

of PROBABLE

CAUSE

Affiant's

Name

-:8~r~a~d.....cV"__'o=..:o~rh:.!.'e~e=s

Occupation ----'P'-oo:.:l~iQ;:z;e_;Off:;.!•..:.:.i.c;::;.;e~r-~[)~a.:.cte::.::e;.::tlv.::.;e:::;.· Assignment Child AbuselSeXual Assault

~No. of Years: 15
No. of Years; 5

years

'lears

Department Employed by Cit\! of Corona Police Department Your affiant received information as follows: Your affiant Detective

employed

by the City of Corona Police Department since November 1996 and was assigned

Brad Voorhees

10# 11·025 (further

referred

to as "I") has been

to the patrol division until 2001. I was then aSSigned to the FLEX Team which .i.sresponsible for working special details and/or programs. Such as; seNing search and ·arrest warrants, Parole/Probation compliance checks, surveillance and Alcohol Beverage Control .(ABC) compliance sweeps. In july of 2005 i was promoted to the rank of Corporai and returned to the patrol division and worked as a Field Training Officer (FTO). In May of 2007 I was promoted to the rank of Detective and was assigned to the Sexual Assault Child Abuse Unit (SAGA). I am currently a member of the California Sexual Assault Investigators Association (CSAIA). In July 2007 I attended a 4 hour SACA training class conducted by the Riverside District. Attorney's Office. In November 2007 I attended a POST certified 24 hour Child Forensic Interview training course sponsored by t.he California Institute on Human Services. In March 2008 I completed an 84 hour Institute of Criminal Investigation (lei) core course sponsored by the San Diego Regional Training Center. In February 2009, I attended a 36 hour Child Death Investigation course sponsored by Fox Valley Training In Corpus Christl TX. In October 2007, March 2009 and March 2011 f attended a POST certified 24 hour Sexual Assault and Child Abuse training sponsored by CSAIA,
_I

currently hold an Advanced Certificate from the Police Officers Standards also possess an Associate's degree from Yuba Community College.

and Training. I

I have conducted and/or been involved with over three hundred investigations; ranging from homIcide, robbery, burglary, embezzlement, sexual assault, child abuse, child pornography, forgery, etc ... These investigations included the interviewin~ of victims, co.llection of evldenee, preservatlon of evidence, arrest of suspects) il'1terviewlng of suspects and crime scene preservation. During these inveStigations, 'I have learned of several different techniques that suspects use to commit crimes and conceal evidence and/or property from law enforcement. These include the LIse of fraudulent ldenti'fication to conceal their true identity and the use of computers and/or cellular phones to contact their victims as well as to conceal evidence. These include the USe of computers, storage data, cameras and cellular phones to

photograph,

distribute

and

store

Inappropriate

images

of

children.

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P,o,GE

07

rA ,"l,~ . ~. "i ~

n O·3
.

f] " l, tv .

7
.

1

On 3-29-12, I was contacted by rkey who wanted to report the physical abuse of a juvenile only known to him Steven told me that he currently resides at 725 W. Tenth St. Corona ca. He I the residence with 5 other adult malea. The home is run by a church based group in the city of Corona and is managed by a person named Lonny Remmers, Steven stated that FIe has known Lonny for approximately 5 yrs., but moved Into the horne approximately one month ago. Steven stated that approximately two weeks ago,. he observed one of tenants who he identified only as DJ (later identified as Jeter Darryl! Duane Jr) and another subject he personally knows as Nick (later identified as Nicholas James Craig) enter the home with a juvenile. Steven said the juvenile was naked when he entered the home and had cuts all over his back. Steven had never seen the juvenile until that time. Steven said he had overheard both Nick and DJ talking about what had happene,d Steven told both Nick ar~d OJ had driven t.he juvenlfe to the desert where he was told to dig his .. hole when, Nick and Q~ begfln to throw ·dirt onto .. an attempt to bury him alive. He said whe~ returned home he took a .. while Steven talked with Nick and DJ. Steven s~hateither Nick or DJ went to the kitchen ~ced some salt Into the paJr~ of their .handS al1~ then w~nt to the bathroom where _was sn .. . Steven saId he heard soreaml1'}9 coming from-the bathroom and assumed it was Steven was later told by an unknown . tnat they had placed the salt into opens wounds that were on the back The following day when Steven arrived home from work he observed broken zip ties on the 'floor of the bathroom and blood all over the inside of the shower. I-Ie was not sure what had happened at that time but was late I' told by.an ul'lknown person that~ was stripped of his clothes and placed into a chair, His hands .and feet were bounc to the chair with zip ties. He then placed lnto the shower and maced or OC sprayed. He also learned ·that to bleed from the mouth or nose which may have accounted for the blo inside the shower. told me that he had. heard from other members living within the home that.

was liying with them because nts mother who also attenps the church had asked Lonny rs to teach her son how to be ~ man and learn responsibilQy_ Steven said
he had also heard fha
__,,;;

-

-

- .. -

._.

-

-

~~--

-

-----~

.

emerged from withln the house and hG1nd~!d pair of pliers to Lon a
his shirt and Lonny, using the pliers, squeezed the nipple
out in pain.

On that same evening (3-19-12) Steven was ~ttending a men's only bible study in the garage of the horne of Lonny Remmers (496 Sloan Dr. Corona said that there were approxi,mately 12 people in attendance as well as . He said that Lonny Remmers asked to sit in the center of the group of . Steven heard Lonny ask someone in the groLlp. "Get me some pliers." A few someone

u~jng him to cry

then lifted

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Steven stated that he often attends church with the men in the home and at the home of Lonny Remmers. He said that on Thursday evenings the group attends church located within a strip mall near Lampost Pizz~ .. ~orth Main Sf. Corona. .

take ~

Based on the statements of Stevena"nd the artanWr detectives to make contact, :

~, ...-s '.'

into protective custody pending' '

of further injury to-'I and the others at the churchaf1d to

n.

At approximately 1830 hours on st. where he identified himself as custody and transported to Corona PD. Once at the station I conducted an interview with_ his statement.

contacted in front of 3~O N. Main He was taken into protective

The following is a summary of

'_stated thal hls he and his mother and sister are members of tOriny"Rernl'lner's church and currently live at homes that he provides. His mother and si$tar'li~ at a home for women and he now lives in the home with the men. He was living with his
mom and sister until app 725 W. Tenth St. Corona CA.

'~;} ~ , ~t<'_~' ".~

ago when he was placed with the men at very reluctant to provide me with any

foQforlfation but later gave great
=;!

incidents.'

t

t

id that he wa~ placed into the home with the men because he had_
~ that he was being disciplined for his behavior and not accepting his actions. twa weeks ago he was driven In Nick and DJ to ,the desert ~as told that he was gain, He stated that approximately

then drb~g
digging. ~said

darkness~tQan unknown desert location.

Nict<IS vehicle by ltotll his own grave. They
was then told to start

he" dlj@ ~r 1 to 1 ~ hours. He was then ' get into the was, told that lfependlng Orl how he acts would determlne if he would leave alille., said he was afraId at he was going to be killed and begged both Nick and. OJ for more chance, as he tried to get out of the hole, Nick and DJbegan to tt;rI'Gf'./$lirt onto im, ' feared that he was , ~o be burled alive. He was also struc~ ~ith belts as he to get out of the hole. was eventuSllly let of the hole and placed back IntotAe vehicle. A'SWthe three o'r were dri'lling home, Nick11i!ll1d DJ stopped at a Denny's restaurant atan unknown location. . told to stay inthe vehicle while Nick and OJ ate inside. in the morning of 3-19-12 they arrived home a.t 725 W. Tenth St. Corona, where was directed to ta;l<e_ 'shower. He admitted that he then sawSteven Larkey in the neuse, ~~d not met him or others in the house prior to that time, , id after showering he was given a blanket and was told to sleep the floor.
,

After waking up later in the day of 3-19-12, he was approached by..a'group of men that he would not identify. '_said he was stripped of his clothing and placed into a

-

0"

'

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chair. He said that both of his hands and feet were bound to the chair with white zip ties and placed in the shower. He was then Maced on his face and was not allowed to wash or cool with water for approximately 30 minutes. During this time he said that his nose began to bleed. Due to the pain of the mace on his face he thrashed his face from side to side causing the blood to splatter on the walls . of the shower. , _'S~:id fhe ordeal lasted for about one hour before the zip ties were cut from his hands and feet and allowed to rinse his face.

"also admitted to attending chu'~h at thehorne Lonny Remmers on the night of 3~19-12. He would only tell me that everything that I had previously told him about what I knew had occurred. He said that Lonny did use a pair of pliers to pinch his left nipple. He denied crying out in pain, or saying to stop. ..

or

Based on my training and experience and the facts contained in this declaration, I believe that the items listed in Attachment "8" will be located at the listed address(s) and vehicle which will enable me to further pursue my investigation. It is my opinion based on traIning anlt experlenee that many individl.lsls utilize various formats of electronic communication and storage/GPS devices which include the USe of cellular phones and computers -both laptop and desktop. Many people communicate with one another by these means and often store personal information, photos, text, messages, e-mails ~nd other correspondences in them. I believe that by obtaining and" identifying any correspondence by the suspect(s) will further enable me to pursue my investigation.
c

It is further requested that a forensic technician, sworn or non-sworn, employed by the ~ity of Cor~na Police Departmen~ be granted authorization to exsil1ine,: m.ake .dupllbate Images/copies of the above ..mentioned recordings/data and to defermrne If evldence of the offenses enumeratedabove are contained therein. Evidence copies of the ItemS,. relating to these offenses will be created and ret~ined for further proceedings and made' available to the authorjties ~ The ernount of data that may be stored in the herd d,ives and removable storage devices is enormous, and the number or size of the hard drives and removable storage devises that will have to be searched pursuant to this warrant is IlOt known. The data to be seized may be located anywhere on the hard drives and rerndvable storage devices, including hidden files, program files, and "deleted" files that have not been overwritten. The data may be encrypted, or inaccessible without a password, and may be protected by selt-destruct programming, all of which take time to bypass.
t .

Only those items recovered under the Search Warrant and relating to the offenses will be retained. The master copy will be retained in evidence storage for later discovery and trial purposes. ,

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1£1

.~.>~ "l11'."L 0 '1 O ~~. £tf -' %J
Q
~I

It is your Affiant's experience that computer system forensic examinations and searches cannot be completed within the ten days in which the Search Warrant must be served and the Return to Search Warrant filed with the Search Warrant. It is requested that the 10-day requirement be waived to provide your Affiant ample time to have it processed and comply with the Search Warrant in a timely manner. The Return to Search Warrant and Search Warrant will be filed promptly upon completion of the computer system forensic examination and search. Due to this being an on-going investigation regarding the torture of a 13 yr. old male victim, where the suspects are the victim's spiritual counselors and the lntormant is a parishioner at the church, I am requesting that the documents related to this search warrant, all attachments and the warrant return be sealed and not be made public. The victim lived in the church's group home and other suspects and I or witnesses may be identified during the service of this search warrant I believe that if the information contained In this search warrant, and related documents, were to be made public, it could jeopardize the investigation by releasing information that only the suspect and/or accomplices would know. This could in turn disadvantage law enforcement in any future suspect interviews. WHEREFORE, I pray that a Search Warrant be issued for the residences located at 496 Sloan Or. Corona CA 92879 and 725 W. Tenth 8t. Corona CA 92882, as well as the vehicle 2001 GMC Yukon CA license 4TJM267. I declare under the penalty of perjury that the foregoing is true and correct. Executed at Corona, California on this 30th day of March 2012.

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IN THE SUPERIOR COURTS OF RIVERSIDE COUNTY, STATE OF CALIFORNIA
Attachment B

DECLARATION

and REQUEST FOR ORDER ,
;

§EALIN'G SEARCH WARRANT

D'OCUMENTS
,

-

Your Affiant, Detective Brad Voorhees, relates that the .Search Warrant sought pursuant to this Search Warrant / Affidavit, Statement of Probable Cause and the Return to Search Warrant and all documents relevant to this Search Warrant relate to an on-going torture investigation. I am requesting that the documents related to this search warrant, all attachments and the warrant return be sealed and not be made public. ! believe that if the information contained in this search warrant, and related documents, were to be made public, it could jeopardize the investIgation by releasing information that only the suspect and/or accomplices would know. This could in tum disadvantage law enforcement in any future suspect interviews. Your Affiant requests that the SearCh Warrant / Affidavit, Statement of Probable Cause and the Return to Search Warrant and all documents relating to this Search Warrant be ordered to be sealed; and that the Search Warrant I Affidavit, Statement of Probable Cause and the Return to Search Warrant and all documents relating to this Search Warrant remain sealed and in the custody of the clerk of the court until further order of this court or other competent court having jurisdiction over this matter. I declare under penalty of perjury that the related foregoing is true and correct to the best of my knowledge, Dated: ?Cl 2012 Detective, Corona Police Department

dZA.¢('i!(

'j

POINTS & AUTHORITIES People'l_Sanchez (1972) 24 Cal. App. 3d 664, 678; People v Greenstreet ('1990) 218 Cal. App. 3d 1516; Swanson v Su~rior Court (1989) 211 Cal. App. 3d 332.

SUPERIOR COURT OF CALIFORNIA County of Riverside
AFFIANT'S DECLARATION Brad Voorhees --------~~~~~~ of PROBABLE CAUSE

.0:4 0 31 2 ff S'

Affiant's

Name

Occupation Assignment

_,_P-:o-0I:.!.:ic:..::e,_O~·:,-,-ff~ic~e!_r-_!:;.D:::...:e:::..!:t~ec::::..:t.:.;iv~e:.__ years No. of Years: 15 Child Abuse/Sexual Assault No. of Years: 5 years

Department Employed by City of Corona Police Department Your affiant received information as follows: Your affiant Detective Brad Voorhees ID# 11025 (further referred to as "I") has been employed by the City of Corona Police Department since November 1996 and was assigned to the patrol division until 2001. I was then assigned to the FLEX Team which is responsible for working special details and/or programs. Such as; serving search and arrest warrants, Parole/Probation compliance checks, surveillance and Alcohol Beverage Control (ABC) compliance sweeps. In July of 2005 I was promoted to the rank of Corporal and returned to the patrol division and worked as a Field Training Officer (FTO). In May of 2007 I was promoted to the rank of Detective and was assigned to the Sexual Assault Child Abuse Unit (SACA). I am currently a member of the California Sexual Assault Investigators Association (CSAIA). In July 2007 I attended a 4 hour SACA training class conducted by the Riverside District Attorney's Office. In November 2007 I attended a POST certified 24 hour Child Forensic Interview training course sponsored by the California Institute on Human Services. In March 2008 I completed an 84 hour Institute of Criminal Investigation (ICI) core course sponsored by the San Diego Reqiona! Training Center. In February 2009, I attended a 36 hour Child Death Investigation course sponsored by Fox Valley Training in Corpus Christi TX. In October 2007, March 2009 and March 2011 I attended a POST certified 24 hour Sexual Assault and Child Abuse training sponsored by CSAIA. I currently hold an Advanced Certificate from the Police Officers Standards and Training. I also possess an Associate's degree from Yuba Community College. I have conducted and/or been involved with over three hundred investigations; ranging from homicide, robbery, burglary, embezzlement, sexual assault, child abuse, child pornography; forgery, etc ... These investigations included the interviewing of victims, collection of evidence, preservation of evidence, arrest of suspects, interviewing of suspects and crime scene preservation. During these investigations, I have learned of several different techniques that suspects use to commit crimes and conceal evidence and/or property from law enforcement. These include the use of fraudulent identification to conceal their true identity and the use of computers and/or cellular phones to contact their victims as well as to conceal evidence. These include the use of computers, storage data, cameras and cellular phones to photograph, distribute and store inappropriate images of children.

On 3-29-12, I was contacted by Steven Larkey who wanted to report the physical abuse of a juvenile only known to him as _ Steven told me that he currently resides at 725 W. Tenth St. Corona Ca. He lives at the residence with 5 other adult males. The home is run by a church based group in the city of Corona and is managed by a person named Lonny Remmers (2-2-58). Steven stated that he has known Lonny for approximately 5 yrs., but moved into the home approximately cine month ago. Steven stated that approximately two weeks ago he' observed' one of the tenants who he identified only as OJ (later identified as Darry!! Duane Jeter Jr. DOB: 2-4-84) and another subject he personally knows as Nick (later identified as Nicholas James Craig, DaB: 11-7-89) enter the home with a juvenile. Steven said the juveniLe was naked when he entered the home and had cuts all over his back. Steven had never seen the Juvenile until that time. Steven said he had overheard both Nick and OJ talking about what had happened . . . St~ve;n to m¢ that both Nick and OJ had driven the juveni to the desert where he was told to dig his own was then nto the hole when Nick. and DJ began to throw dirt . h an attempt to bury him alive .. He said when returned home he ·took a s ower while Steven talked with Nick and OJ. Steven that either Nick or OJ went to the kitchen and. pi ome salt into the palm of their hands and then went to the bathroom where was showe~.teven said he heard screaming coming from the bathroom assumed it was~ Steven was later told byan unknown. that they haa placed the salt into the opens wounds that Were on the back of . The following day when Steven arrived home from work he observed broken zip ties on the floor of the bathroom and blood all over the inside of the shower. He was not sure what had happened at that time but was later told by an unknown person that _ was stripped of his clothes and placed into a chair. His hands and feet were bound to the chair with zip ties. H~ was then placed into the shower and maced or OC sprayed. He also learned tha_began to bleed from the mouth or nose which may have accounted for the blood 'splatter inside the shower. Steven told me that he had heard from other members living within the home that _ was living with them because his mother who also attends the church had asked Lonny Remmers to teach to be a man and learn res said he had also heard that On that same evening (3-19-12) Steven was attending a men's only bible study in the garage of the home of Lonny Remmers (496 Sloan Dr. Corona CA). Steven said that there were approximately 12 other people in attendance as well as". He said that Lonny Remmersask~d _ to sit in the center. of the group of men. Steven heard Lonny ask someone In the group, "Get me some pliers." A few moments later someone emerged from within the house and handed a pair of pliers to Lonny. _ then lifted his shirt and Lonny, using the pliers, squeezed the nipple of_ causing him to cry out in pain.

Steven stated that he often attends church with the men in the home and at the home of Lonny Remmers. He said that on Thursday evenings the group attends church located . within a strip mall near Lampost Pizza on north Main St. Corona. Based on the statements of Steven and t~ntial of further injury to" I arra '.. for detectives to make contact with _nd the others at the church and to take into protective custody pending further investigation. At approximately 1830 hours on 3-29-J, contacted in front of 380 N. Main St. where he identified himself as ' He was taken into protective custody and transported to Corona . station I conducted an interview with". The following is a summary of his statement. '_'stated that his he and his mother and sister are members of Lonny Remmer's ~and currently live at homes that he provides. His mother and sister live at a home for women and he now lives in the home with the men. He was living with his mom and sister until approximately tw.o weeks ago when he was placed with the men at :25 W.. Tenth st. Corona CA. "w.as. very relucta~t to provide me with any mformation but later gave greaLde"taii'Oftfie incidents. he was placed into the home with the men because he had_ and that he was being disciplined for his behavior and not accepting actions. He stated that approxirn two weeks ago he was driven in Nick's vehicle by both Nick and OJ to the desert. was told that he was goi to.di his own grave. They then dro ring darkness an unknown .desert location. then told to start di~gin . said he dug for 1 to 1 Y2hours. He was then told to get into the nd ,... pending on how he acts would determine if he would leave alive. ...... d that he was, going to be killed. and begged both Nick and OJ for one more chance. at as he tried to get out of the hole, Nick and OJ began to throw dirt onto m. . re.d that he was g~ be buried alive. He was also struck with belts as he Wed to get out of the. hole. _ was eventually let of the hole and placed back into the vehicle. As the three of them were driving home, Nick and D,J stopped at .a Denny's restaurant at an unknown locatlon. was told to stay in the vehicle while Nick and OJ ate inside. ~. arl '. the morning of 3.-.19-12 they arrived home at 725 W. Tenth st. Corona, where __ was directed t~a shower. He admitted that he then saw Steven Larkey standing in the house._had not met him or others in the house prior to that time. _ said after showering he was given a blanket and was told to sleep on the floor. After waking up later in the day of 3-19-12, he was approached by a group .of men that he would not identify.~said he was stripped of his clothing and placed into a chair. He said that both of his hands and feet were bound to the chair with white zip ties and placed in the shower. He was then Maced on his 'face and was not allowed to wash

or cool with water for approximately 30 minutes. During this time he said that his nose began to bleed. Due to the pain of the mace on his face he thrashed his face from side to side causing the blood to splatter on the walls of the shower. _said the ordeal lasted for about one hour before the zip ties were cut from his hands and feet and allowed to rinse his face. '_also admitted to attending church at the home of Lonny Remmers on the night of 3-19-12. He would only tell me that everything that I had previously told him about what I knew had occurred. He said that Lonny did use a pair of pliers to pinch his left nipple. He denied crying out in pain, or saying to stop. I was told by the RP that both Nicholas Craig and Darryl! Jeter work at a construction site near the intersections of N. Main St. and Rincon Ave in the city of Corona. He also provided me with a description of Craig's vehicle. On 3-30-12, I directed Det. Gonzalez and Det. Taylor to that area in an attempt to locate Nicolas' vehicle as well as Nicolas Craig and Darryl! Jeter. Both Craig and Jeter were located outside the construction site located in the 200 block of W. Rincon. They were taken into custody and transported to CPO pending further investigation. On 3-30-12, I prepared search warrants for the residences at 725 W. Tenth S1. and 496 Sloan Dr. Corona Ca. The search warrants were approved by the Honorable Judge Sichel of the Riverside Superior Court. While serving those warrants, SU01 Lonny Remmers arrived home at 496 Sloan Dr., Corona CA at which time he was contacted by Det. Bloomfield. While in the driveway of his home and out of custody, Detective Bloomfield inquired with Lonny Remmers about the incident. Det. Bloomfield told me that Lonny Remmers admitted to telling Nicholas Craig and Darryl! Jeter to take _ someplace and scare him. He also admitted to using pliers to squeeze the nipple cif ."during a bible study at his (Remmers') home. .. . On 3-30-12, during Miranda interviews with Nicolas Craig and Darryl! Jeter, both of them admitted to d to the desert and having him dig a hole and forcing him to get in. They then threw onto him while he was in the hole, but did so only to scare him. They denied having any knowledge as to how suffered a bloody nose or being strapped to a chair and pepper sprayed. . During a search of 725 W. Tenth St., Corona, 10 Tech L. Walker located and confirmed blood splatter on a bedroom wal! directly outside the bathroom where ~advised that he was bound, maced and ultimately suffered a bloody nose. Other items of clothing belonging to _ or possibly Nicholas Craig or Darryl! Jeter were also seized at the time of ar~d during the service of the search warrant. These items also had what appeared to be blood stains on them.

Based on my training and experience, I believe DNA testing and comparison will enable me to further pursue my investigation by identifying the source of the blood splatter found within the home of 725 W. Tenth St. Corona Ca, as well as prove or disprove the (suspects) proximity to the victim during the commission of the crime .

Therefore, I request permission to obtain a blood or buccal swab sample for DNA testing/comparison from, Nicholas Craig and DarryJl Jeter who are currently in the custody of the Riverside County Sheriff's Department. I also request permis~JQ)tl_ tg o.Q~~i.n? blood or buccal swab sample for DNA. testing/comparison from .. ~ who is currently in protective custody with the Riverside County Department of Social Services. A Buccal swab is the least intrusive method of obtaining a biological sample. The ~ sample will be submitted for comparison/confirmation only relating to this case and not filed with DOJ's data bank of DNA. WHEREFORE, your Affiant 'prays that a collection of Nicholas Craig, Darryll Jeter an for the DNA

I declare under the penalty of perjury that the foregoing is true and correct. Executed at Corona, California on this 3rd day of April 2012. . ,
'.

... ...

IN THE SUPERIOR COURTS OF RIVE,RSIDE COUNltrU 3 STATE OF CALIFORNIA
Attachment B

'J

2 ",8~

DECLARATION and REQUEST FOR ORDER SEALING SEA'RCH WARRANT DOCUMENTS
Your Affiant, Detective .Brad Voorhees, relates that the Search Warrant sought pursuant to this Search Warrant / Affidavit, Statement of Probable Cause and the Return to Search Warrant and all documents relevant to this Search Warrant relate to an on-going torture investigation. I am requesting that the documents related to this search warrant, all attachments and the warrant return be sealed and not be made public. I believe that if the information contained in this search warrant, and related documents, were to be made public, it could jeopardize the investigation by releasing information that only the suspect and/or accomplices would know, This could in turn disadvantage law enforcement in.any future suspect interviews. Your Affiant requests that the Search Warrant / Affidavit, Statement of Probable Cause and the Return to Search Warrant and all documents relating to this Search Warrant be ordered to be sealed; and that the Search Warrant / Affidavit, Statement of Probable Cause and the Return to Search Warrant and all documents relating to this Search Warrant remain sealed and in the custody of the clerk of the court until further order of this court or other competent court having jurisdiction over this matter. I declare under penalty of perjury that the related foregoing is true and correct to the best of my knowledge.

Dated: April 3, 2012

POINTS & AUTHORITtES
People v Sanchez (1972) 24 Cal. App. 3d 664,678; People v Greenstreet (1990) 218 Cal. App. 3d 1516; Swanson v Superior Court (1989) 211 Cal. App. 3d 332.