1:15/17/2612'.

, ~

8188331423

SF

[fA

SUPERIOR

COURT OF

THE STATE

OF CAL~'"

~~

~ 'Y).>

FOR THE COUNTY OF LOS ~~~~~~~~~~~

ANGEI.ES ~~~~
CASE

'?-~
~

~ (b~ ;if-~o.? .0:
~h~

TH£ PEOPriE OF-THE STATE v.

OF CALI}'ORNrA.,

NO. PA07t543

Plaintiff,
AMeNDED FELONY COMP.l.A..lNT Defcndant(s .

»~

-'-'f"

COUNT 1

.On or between September 13,2010 and April 15, 2011,
• ,~

,

in

{he County of Los Angeles, the crime of
I'.

CO]'.."TINUOGS-SEXUAL ABUSE, In violation of PENAL CODE SECTION 288,5(a), a Felony, was

committedbi' ~At}L CHAPEL,

who did unlawfully

engage in three and more acts

Of"lfIlbstantial5exual

conduct", as'defined in Penal Code Section 1203-066(b), and three and more lewd and lascivlous acts, as d ~fil'i.l:d P~n.1!JCod e Section 28 8, withe Ch.i~dI 1. ,in
defen dant resided with I and had recurrin g access to,
,

lac h ild under the ag~ of 14 years, whi J e the the cIJ lid.
.

"NOTICE~ Th~eabove offense is a serious felony within the meaning of Penal Code section \ 192.7(c),"

"NOTICE; Conviction
Willful failure evidehee
to

of this offense

will require to register

pursuant

to Penal Code section 290 et seq,

register Is a crime, H
test

"NqTT€B:' O:\nyiction oflhi.!! offense will require the court to order you 00 submit to" blood

for

o.f a_n,tilxxlies
sectIon

to the probable causative ageat of Acquired Immune Deficiency Syndrome (AIDS).

Penal Code ~NOTICE:

1202, I."

:Bein,g charged

with this criminal offense can result in mandatory pre-conviction HIV/AlDS

testing and di SG losure of tbe results

to a victim and the Chief Med ical Officer of the jai I or pri son facil it)'
to

wnere you are incarcerated 121055 ioftowing_1!
probable

pursuant

Penal Code Section 1524, 1and Health and Safety Code section resulting In a court
order."

cause

hearing

* '" * *,.

Page 1

Ca:i,.eNo. PA07i543

FELONY COMPLAINT

8188381423:

SF ~,

PAGE

el3/31

COliNT2

.with . years,

Ifle )jQity

.and certain
of
.

parts and members appealing

thereof

Ofl Child 1
gratifying the

I,

a child under the age of fourteen and ~exU8.1desires of the.

with. the,.!intent

saiel defendant

"

arousing,

to, and

lust, passions,
to

and

the

said child.
0 f til j ~ offense

"NOn c:E~ ton vi ction
,
,
)
,

will roqo ire to reg] srer pursuant

Pen a! Code 5ection 290 et seq,

W,illfnl failure l¢l;register IS a crime."
.. .

"NOTI€E: :ruJ:~I.I"llt to Penal Cod" Sections 11 ).66 and 11168, a Suspected Child Ab,liSe Report (SCAR)
'
'

, may hav~ been generated in this case.
protective

Penal Code Scctlons

l l 167 an"

1,1167.:;

1im it a(:(:E::,!S to a

SCAR,

A

order _jSrlUEXI a court is necessary by

to obtain a copy of the report,"

''NOTICE: The above offense is e. serious felony within the meaning of Penal Code Section 1192.7(c) and a
, :r.,

;.violen~felony ."..ithin the meaning
~ '..

of Penal Code Section 667,5(c).I'

"NOT,ICE: 'C~tlvi\;tiOll of this offense will require the court to order you to !lubmit to "-blood test for
i!i:
,

evidence of ahtibodies to the probable causative agent of Acquired Immune Deficiency
Pen al Code section 1202. 1."

Syn<!rome (AIDS).

epse No, PA071!}!3

F,ELONY COMPLAINT
.....

-.. ------_--

9188:39142:31

SF DA,

PAGE

a4l31

COlJi'IT3 On

a~?etween

September in

]3,2010

and April 15,2(111, in Ihe County

of Los Angeles,

the crime

of

LEWD AC! UPON A CHlLD.

violeticn of PENAL CODE SECTION 288(a), a Felony, was committed
0

by~PAL1L CHAPEL, who did willfuJly, unlawfully, and lewdly commit a lewd and lascivious act upon and with the body and certain parts and members thereof years, with the-intent of arousing, appC!aling to, and gratirying the lust. passions, and sexual desires of the
of til iB offense will req u ire to register pursu ant 10 Pena.l Code: section 290 et seq.
n

~

,

'ON UTI CE :..Con

\I

j ction

Willful failu~,to register is a crime.
"K()TICE:

~~r~uant to Penal Code Sections 111 ti6 and I 1l68, a Suspected
Code

Child AllUS~ ~eport to

(SCM)

may havlI:Jjllien·gen~l"8tcd ill this case. Penal

Sections 11167 and 11 Ui7.S limit access

a SCAR.

A

protective order issued by a court is necessary to obtain a copy of the report"

"NOTICE~ The above offen~e is a serious felony within the meaning of Penal Code See-don 1I92.7{c) and a violent felony wl!hin the meaning of Penal Code Section 667,5(c)."
['NOTICE: . C.o~vjction of this offense evidence of ~~tib?diel'l to

will require the court to ower ~ou to submit to a blood test for
causative agent

t~t probable
,n

of Acquired 1mm.IlT\~ lJeficiency

Syndrome

{AIDS),

Penal Code

s~c:iion]202.1

Case No, PA071543

FELONY COMPLAINT

8188381423

.SF DA

PAGE

El5/31

COUNT
Olior between
." • "O!I"'

4

Septern ber 13, 20 IO 311 d April l 5, 2011, in

th e County

of Los Angeles,

th c cd me of

U;_WrJ ACT UPON A CIDLD,

in violation QfnNAL CObE
unlawfully, thereof

SECTION

288(8), a Felony, was committed

by PAw;.;-C~EL,
L ", ~ ~

who
-

did willfully,

and lewdly commit a lewd and lascivious act upon and
0

wlth the body and certajn parts and members

years, with lbe·intent

.

-

ChUd

1

,a.

child under the age of fuurteen

of arousiug,

appealing

to, and gratifying

the lust, pIL'!SiOnR, and sexual desires of the

. said defend~nt.and the said child. "NO~ICe:" Ojn\ljctj~ ofchis offense will require to register pursuant to Penal Code section 29() et seq. 11] 66 and t 1 j 68. a Suspected Chi Id Abuse Report (SCAR)
11167 and 11167.5 limit access to a SCAR. A

Willful failure to register is a crime." "N OTICg: Pursuant
i-: ~
'II:

to Penal Code Sections in this case.

J"

may have been generated

Penal Codt Sections

protective order i:s:>ued by. court is necessary to obtain a copy of the report."

,

"

''NOnCE; The above offense is 2. serioes felony within tho mean in 8 of Poena 1Code ~cti on 1192.7(c) and a
violenr'felonywithin
"NOTICE:·
~ • " t-

the meaning ofPenal Code Section 667.5(c)."
of this offense will require the court to order you to submit

COnviction

to

It blood test for

. evidence of antibodies to the probable causative agent of Acqulred Immune Deficiency Syndrome (AIDS), Penal Code section 1202.1,"

'" '" * ""'"

C_BU

No. PA07'543.

FELONY COMPlAINT

8188381423

SFDA

PI"oGE 05/31

COL~TS
011 or betwltcn September 13, 20lQ snd April 15, ZOI 1, in the County of Los Angeles,

the crime of sexual
as

CO"NT.!NUO;U~ SEXUAL ABUSE, in violation co~miUed
conduct",

ofPF.-NAL CODE SECTION 288,5(a),

a Fd{lBY, was

by PAUL CHAPEL,

who did unlawfully
Section

engage in three and more acts of "substantial

a~ defined
in Penal,

in Penal

Code

ddin~

Code Section 28~, with

I

1203.066(h),

and three

and more lewd

and hUCIVLQUS acts,
while

ChBd 2

III

child under

the age (If 14 years,

the

defwdant resided with. and had recurring access to, the child. '''NOtiCE:- , 'the: above offense ,is a serious felony within the meaning of hmat Code section 1192.7(.;)." . ''NOTICE: Conviction of this offense will require to register pursuant to Penal Code section 290 et ~eq.
~ WI) lfll j fai lu~ to rl!gi ster is a crhne_ " '<NOTICE;

e0T,lvlction of this offense will require

the court 1:0 order

you to submit

to a blood test for

evidence of antibodies to the probable causative agent of Acquired Jmrnune Deficiency

Syndrome (M05).

Penal Code sectioll 1202.1."
"\TOTICE;

Beil;g charged

with this crimlnal offense can result in mandatory pre-convicticn
i! nd

HJVJAlDS

testi ng ar.u.t disc] osure of the reso Irs to a victim

the Ch ief Medical Officer of the .i ai I or prison facility

where you are i:ncru-ceratedpursuant to Penal Code Section 1524.Iand Health nnd Safety Code section J 2105:} fo 11OWl ng a pro babl e cause hearing resu lting in a court order,
I'

FELONY COMPLMNT

6188381423

SF DA

PAGE

e7!~1

COU'NT6 Clrror between February 1,2011 and April 15,2011. PORCfBLE
was eomm~~~d by PAUL

in the County of Lex«Angeles, the crime of a felony,

LE\VD ACT UPON CHILD, in violation of PENAL CODF. SECTION 283(b)(1).

CHAPEL,

who did

wiTlfuHy, unlawfully. and lewdly

(;{)mmit a lewd and

-: i~Ci v j~\I~ ~t7u-pon and with the body and certain parts and members thereoforj
. and sexua.,1desires of the

Child 2

I,

schild

under theage of faurte.t:!n years, with the intent of arousing, appealing to, and graritYtng the lust, passions,

,aio dcf~lIldant and the said

child, by use of'foree, violence, duress, menace" and

threat of great bodily harm

- "NOneJ;.:
"NOTTeE:

Tblt above offense is 11 serious felony within th~ meaning of Penai C<1dc:Section l192_7(c) and a
'Gonvrction of this cifen:;c will require to t't:gister pursuant to Penal Code section 290 et seq,

.~violent felony: ':,t~thin the mean; ....@' of Penal Code Section 667.5(c)."

Willful failure to register is a. crime."
"NOTICE: Pursuant to Pet)al Code Sections t 1166 and 1 J 168, a Suspected Child Abuse Report (SCAR)
<

I

may have be-ell generated ill this C8S~. Penal Code Sections 11167 and 1 J 167.5 1innt access protective order issued by a court is necessary to obtain a copy of the report."

to

a SCAR_ A

., . "NOTICE: Conviction of this offense will require the court to order you to submit to a blood test for

evidence of antibodies to the probable causative agent of Acquil'Cd Immune Deficiency Syndrome (AIDS). Pt::nHICode section 12V2.L"

pagelS

Case No. PAG71!iS.,

FELOJ\T COMPLAINT

8188381423

SF DA

PAGE

138/31

COUNT 7 Ol~ f)~ between February 1, 2011 and April 1.5,201 I, in the County of Los Angcles, the crime of
. .~ was commiti<td by PAUL CHAPEl., who did wHifully, unlawfully, and lewdly commit a lewd a.nd

FORCTBLELffiVD ACT UPON CI-llLD, in violation {lfPENAL CODE SECTION 288 (IJ)(J ), a Felony,

la~dvimls al!~upon and with the body and certain parts and members thereof

Ofl

ChUd 2

I,

!I

child

under toe age of. fourteen years, with the intent of arousing, a.ppealjng to, and gratifying the Iust, passions,
and sex~al dcsit!:5 ofti1e . tht'ellt ofgr!:al
, = .

sajd ddtmda.t}t;:md the

said child, by use of force,

violence,

duress" menace,

and

bodily harm,

"NOTICE: The.above offense is a serious felony within the meaning of Penal Code Section 1192,7(c) and a violent felOllywithin the meaning of Penal Code Section M7,S(c).'t "NOnCE: CanVJc:tiOll of til is o:tfe:n::;e will require to register pursuant
is a crime."

to Penal Code section 290 et seq,

W illful failure to register

"NOncE:

Pursuant to Penal Code Sections 11166 an~ 11168, a Suspected Child Abuse Report (SCAR)
!l court

rn:DY 113 \it! be eT1 generated in th ~ Ca5G. Penal Code Sectjon s 1\ Hi7 and 11 167.5 Iim It access ro (1 SCAR. A S protective order i~st.u::d~ is necessary to obtain a copy of the report,"

;;NOTICE: Conviction of this offense will require the court to ora>::r ou to s\lbm!t. to a blood t~t y
pg~~1 cOde s~ction 1202.1."

fOT

evidence of antibodit:lSto the probable causative agent of Acquired Immune Deficiency Syndrome (AIDS).

Page 7

CEI"e No. PA,071543

FELONY COMPLAINT

8188381423

SF.DA

PAGE

aS/31

COUNTS
011 o,f1between February l, 2011 and April 15, 2{tl I, in the County ofl...os Angeles, the crime of FORcmLE;tE~VD ACT UPON CHILD, in 'lito1ation of PENAL CODE SECTION 28E(b)( I), a Felony, Was committed by PAUL CHAPEL, who di~ willfully, unlawfully, and lewdly commit a lewd and lasciv ious acr upon and witb the body an d certain parts and members th~of o~

Child 2

I. IIchi ld
.

under

the

age of

foll11:een

years, with the

intent

of arousing. appealing

to, and gratifying

the lust, pass-ions..

.

and ~eJC1l31dti5in:5.oftltl£
thrcat- of great

'..bodily

said defendant and the said child, by use of force, violer.ce, duress, menace, and

harm,

"NOTf CE; the a Dove offense is a seri ous felony within rile meaning of Pen al Code Section 1 192_7(c) an d a

vio\e~t felony
"NOTkE:

~cjthjn

the meaning of Perla] Code Section
of this

667.5(1:)_" to P~1'JalCode section 290 et seq.

Conviction

offense will

require to

register pursuant

Willful failure to register is a crime." "NOnCE: Pursuant to Penal Code Sections lll66 may have been generated and 11168, a Suspected. ChHd Abuse Report (SCAR) in this case. Penal Code Sections 1 I 167 and 11.167.5 limit access to a SCAR. A

protective order" issued by a court is necessary to obtain a copy of the report."

"NonCE: Conviction

of thls offens.: wi[! l-equire the court

1.0

order you to submit to a bleed test for Immune DefiCiency Syndrome (A IDS).

~\I.id¢J;H"~Jf ant!bodl~ to the probable causative i Penal Cad e sec\i on 1202']."

agent of Acquired

Case No,_PA071543

FELONY COMPLAINT

131S83S1423:

SF DA

PAGE

16/:31

COlJNT9
Qn or',betwaon September B, 20] () and April 15, 2011, in the County of Los Angeles, t:l1ccrime of CONTINU0~S SEXUAL It\B"GSE, in violation of PEN At CODE SECTION
Code Section J

:zltS.5(a.), a felony, was

cammit1l;d by PAUL CHA PEL, who did unlawfully engage in three and more sets of "substantial sexual

con<!L1GII', defined in Penal as
defined resided with, and had recurring

203.066(b)) and three

and

more lewd

and

lascivious acts, as

in Penal Code Section 288, witl1l

Child 3 ~a

child under tf1.~ age of 14 vears, while the d~fen-dant

access to, the child.

"NO:f<JCE: The above offense is a serious felony within the meaning of Penal Code section tl9l.7(c)." '''~6TICE:
WillfurfalJlire
-

Conviction of this offense will require to register pursuant to :Penal Code: section 29I'J ct

seq,

to register is a crime." ~ .. "N'OTlCE: Ci:lTwict!on ofthis offense will require the court to order you to submit to a blood test for e.... idence of antibodies to the probable causadve agent of Acquired Immune Deficiency Penal Code section 1202, I." Syndrome (AIDS),

"NOTICE: Beirg charged with this criminal offense can result in mandatory pre-conviction
teslillg'imd disclosure of the results to a victim and the Chi e f Medical Officer of the jailor wh ere you are incarcerated

HN/NDS prison fadlity

pursuant to Penal C ode Section 1524.1 an{! Health and Sa.:f-E1)' Cede sectl en ~ J 21 055 fa IIowin g a probable cause h .!lrlng resu mug in a court ord er."

Cpse No. PA071543

FELONY COMPLAINT

8188381423

SF DA

PAGE 11/31

COUNT 10
On or'~tween September 13~20)() and April 15, 2011, In the County of Los Angeles, the crime of

LEWD ACT UPO'f A CHILD, in violation of PENAL CODE SECTION 2S8(d), a Felony, was committed
by P~\UL CHAPEL, who did willfully, uBl.awfLlIly, and lewdly commit a hJwd and lascivious act upon and with the body and certaln parts and members 1h=r~ofotl with the ['1t!!nT.,nf arousing, appealing , defendant and the said child, "N'OTTc:E: Con';iction of this offense will require to register pursuant to Penal Code section 290 et seq, Wltifl~l fmlurc

Child

31. a child under the age of fourteen years,

to, and gratifying the lust, passions, and sexual de!li~ offill': said

ro register

,,_'

is a crime." SCAR. A

"NOTICE: ,F'lII:liuant to Penal Code Sections 11166 and 11168, a Suspected Child Abuse Report (SCAR) may hS\Je bem generat£d in this case, Penal Code Sections 11167 and 1I167.S limit access to protective order issued by a court is necessary to obtain a eepy ofthf: report."
1;\

.,
"NO)lCE~ The above offense is a serious feI('Inywithin the meaning of Penal Cede Section 1192,7(c) and a violent felony within the meaning of Penal Corle Section 667.S(c),"

''NOn,CE;' Convlctlon of this offense will require the court to order you
Penal Code $~ctlC[l.1202,1.'·

to submit to a blQQd test for

evidence of antibodies to the probable caJusative agent of Acquired Immune Deflclency Syndrome (AIDS},

Pagg 10

Caoo No. PA071 S!l

FELONY COMPLAINT

9198391423

PAGE

L2!31

COUNT 11
'~Il

o~ [l:e{ween Sepu:tnbt:-r 13,2010 and Aptil ] 5,20) I, in the County of Los Angeles, the crime of CODE SECTION 288(a),

J~EWD ACT 1)PO~ A CHILD, in violation (lfPENAL
byf'AUL CHJ.!,V,"EL,who did willfully,

a Felony, was committed
act upon
lind

llnla.......t'ully, and

lewdly commit 11lewd lind lascivious

wi til th c body ~n d

certain parts and members thereof ofi

C h ild

31,

It C hild

under 1he age of fou rteen years,

with the intent of arousing, appealing defendant and the said child .
• ''NOTICE: Cl)llvlction ofthis

to, and grarifyirtg the lust. passions,

8f1.0 sexual desires of'fhe said

oifense win require to rogi$u:r pursuant to Penal Code section 290 et seq,

Willful, fai'lufl:l to 'regrster ts a crime." . "N OTICE: Prirsuant to Penal Code S ectlons 11 166 and 1 I H18, a Suspected Ch ild Abuse Report (S CA R) . may have been generated in t[,ls case, Penal Code Sections 11157 and 11167.5 limit access to a SCAR. A protective order.issued by a court is necessary to obtain a copy

.".

anne report."

"NOTJe!'.;

fh~,~bf.lye offense is a serious felony ..... ithln the meaning of Penal Code Section of Penal Code Section 667 .5{c).·'

II StZ. 7 (c) and a

violent felony wiilifu the meaning "NOTICE: evidence

COJl~ictiQnof1t1is offense will require the court to order you to submit to a blood test for
of antibodies

to

the

proba.bk

causative

agent of Acquired

Im.mun~ Deficiency

Syndrome

(AJT)S),

Penal Code section 1202.1."

Page 11

FELONY COMPLAINT

.B5!l7l2B12

SF' DA

PAGE

13/:31

COlJNT 12

On or between September

13,20 I0 and. Apri115,

20 I I, in the CO[Jn1'yof LO:l Angeles, the crime of

LEWD·ACT lJPON A CJULD, in violation of PENAL CODE SECTION J88(a), a Felony, was committed by PAUL CHAPEL .•who c1id willfully, unlawfully, and lewdly commit a lewd and lascivious act upon and with thellody.~nd certain parts and members thereofO~ defi:ndant ~d· tl'iclkaid cbiJd.
"NOTTCE:

Child

31, a child under the age of fourteen years,

with tlllilintent of arousing, IPPi:&Iingto, and gratifyin.g the Just, passions, and sexual des ires of the said Co~vlctioll of this offense will require to register putsuant to Penal Code section Z9(J et seq,

Wi!lf~1 fai.lure,'i:(] register is a crime." "NOTICE:

p\_lr~lJant to Penal Code Sec.tlOTls 11166 and \1168, a Snspected Child Al;Ju$<:: Report (SCAR)
Code

l~ay have' b~n' generated ill this case, Penal

Sections 11161 and 1I 167.5 Iiltl it access 10 a SeA R. A

protective order issued by a Court is necessary to "brain a copy of the report.'

"NOTICE: T~E:above offense is a serious felony within the meaning of Penal Code Section 1192.7(c) and a viol ent felony wlthin the meaning of Penal Code Section 667 .5( c)." "NOncE: Conviction of this offense will require the court to order you to submit to a blood test for eV!deIl~ of 8tltih.)dks to the probable causative agent of Acquired Immune Deficiency Syndrome (AIDS). Penal Code section i 202.1"

PMe 12.

Case No. PAG71M;l

FELONY COMPLAINT

8188381423

SF DA

PAGE

14/31

COUNT 13
Olr I!f L~tween Septernber 13..2010 and AprillS, 201l, in the County of'Los Angeles, the crime (If CONTINUOUS sexUAL ABUSE, in violatiot\ of PENAL CODE SECTION 288.5{1l)' a Felony. was committed bY~AUL CHAPEL. who did unlawfully engage in three and more acts of "substantial sexual conduct", as defined in Penal Code Section 12D3.066{b), and three and more lewd and lascivious

acts, as

defined in .Pe.u;£code Section 1.88, wlthl

Child 4 ~e. ~ild under tho age ()f 14 years. white the

defendant resid¢d with, and had recurring access to, the child . . "NOTICE; The above offense is 3 serious felony within the meaning of Penal Code section 1192.7(c)."
"NOTrcE.~

.

Conviction ofthill offense

wi\l rtquu'e

to regt~rer pursuant to

P¢llI'Il Qlde section 290

st seq,

WilTfJ11. failure to register is it crime." ":\fOTJCE: Conv,icti<JDof'this offense will require the court to order you to submit to a blood test fur

evidence of aotihodie.s to the p,obable causative agent of Acquired Immune Deficiency Syndrome (AIDS).
Penal Code Section. 1202. Lrr "l'iOnCE: Being charged with this criminal offense can result in mandatory pre-conviction HIVIAJDS resting and disclosure oftb~ results to a victim and the Chief Med'ci.\l Offl'C~rof the jailor prison facHity where you am incarcerated pursuant to Penal Code Section J524.land Health and Safety Code section 121055 following a probable cause hearing resulting in a court order."
,

Rev. 900·1199

Page 13

CilSi No. PAOZ154~

FELONY COMPLAINT

i?l5/l7!21J12

].7;·][3

"8188381423

SF DA

PAGE

15/31

COUNTJ4
On Lf;WDACT
(If

between Septtmbel' 13. :2010 and

April 15,2011,

if] the County of Los Angeles, the crime of

1'JP.oN A CHILD, in violation of PENAL CODE SECTION :288(a). a Felony, was committed

'by PAUL CHAPEL, who did willfully. unlawfully, and lewdl commit a. lewd 8J1d lascivious act upon and
witl1

the:

body and

certain

pam

Il.l'Idmembers tbereof
appealing

of

ChUrl

4

, a child

under the age of fourteen

years, with the intent of arousing, sl'.i.d defendant ''NOTICE: a~i:!the said child.

to, and gratifying the lust, passions, and sexual desires of the

Conviction

of this offense will require to register pursuant to Penal Code section 290 et seq,

Willful failure I~ register Is a crime, ,.
"NOTfCE;

l'ursual~~to Penal Code S~~tions 1116.6 and 1] HiS. a Suspected

Child Abuse REport (SCAR) to a SCAR,

may have been 'ger.erated in this case. Penal Code Sections 11157 and 11167,5 limit access
protective order issued by a court is necessary to obtain a copy Qfthe report."

A

til'\(HICE: The-above offense is a serious felony within the meaning ofP~nal Code: Section 1192.7~c) and a .
violent felony 'witl:iill the meaning of

.

Penal

Code Section 667.5(c)." the court

"NOnCE: Conviction of this offense will require
evidence of amibodies to the probable Penal Code: section 1202.1."

to order

you

to submit to a blood
Deflcicncy

test

for

causative: agent of Acquired

Immune

Syndromt: (AIDS).

Page 14

case

Ng. PA071.543

FELONY COMPLAINT

---.,t:l5fl ~t20'l. 2 ' 11: t{

, 8196::3914:23

SF DA

PAGE

16/31

COUNT IS

,
,

.

On
.

IH
,',

-

l,\etw~ll:nSeptember 13, 20T(l and AprlI 15,2011, in the County ofT..(l$ Angeles, Ih~ crime of
"

LEWD AC~UPON A CHILD, inviol.tflion of PENAL CODE SECTION28~(a),
by PAUL CHAYE1., who did wiltfully, unlawfully,

a Felony, was committed

and h:wdly commit a. lewd and lasclvieus !Ct upon and
0

with the bo dy and certain parts and mem bers thereof
years,

with the

intent of

arousing, appealing

to, and grati

mg tile

lust,

passions"

2J1d sexual desires

of the

said defendant

and the said child,
10 Penal

"NOnCE: Conviction of this offense wi II require to register pursuant Wi llfu 1 fai I~re to r~gistw is a trim e. or
iii

Code section 290 ct s~q,

"NOnCE; Purstiant to Penal Code Sections 11166 and 11168,
may have he en generated pro te cti ve 0 rder in Hils case.

Suspected Child Abuse Report (SCAR)
[lCCeS5

Penal Code Sections 11167 and 11167 _5 limit
to obtain a copy of the

to a SCAR. A

iss.ued by

a court is necessary

report. "

'"NPTTCE: The above offense is a serious felony within the meaning (ltP¢nlll Code Section 1192,7(c) and a violent felony within the meaning of Penal Code, Section 667.5{c).'f
'"NOTICR evidence
-

Conviction

of

this

offense wilT requi]"€ tIll court to order

you

to submit to

II.

blood test fur Syndrome (AIDS).

of antibodies til the probable causative

Pen al Code secti on ) 202, 1 ."

..

,

agent of Ac.quired Immune Deficiency

Page 1;L

case

NQ, UO:7JS43,

FELONY COMPLAINT

~5/17121=j12

1.7:i3

-

8188381423

SF DA

PAGE 17/31

COUNT 16 . On or berwecn Septernbet lJ, 20 lOan d April 15, :2 0 H, th C COunty of Los Angele
II. Felony,

ill

5,

the crime of

LE\VD ACT UPON A CHTLD, ill violation of PENAL CODE SECTION 28:B(a),

was committed

years, with the'intent of arousing, appealing to, and srallfyirl!: the lust, passtens, said defendant and the said child, ";'(OTICE:- 'Conviction of this offense will require to register pursuant Willful faiju~ to register is a crime"
to-

and sexual desires of the

Penal Code section 290 et seq,

"N OTfCE: Pursuant to Penal Cod e Sections 11166 and 111 (j 8, a Suspected Child A buse Report (SCAR)

may have been Jgenernted in th Is elise _ Penal Code Sectio ns J 1167 and 11 J 67 j limit access to a SCAR_ A
protective order t~$ued by a court ts ne-cessary to obtain a ropy ofthe report."

-I

"NqTICE: ~c above offense is a serious felony within the meaning of'Penal Code Section 1192,7(c) and a
violerrt

ftionywirlJin

the meaning of'Penal Code Section 667,5(c),"
to

";\TOTlC£;

Con: . ict!on ofthis offense will require the court .
"

order you to submit to a blood test for

evidence of ~lib~dit;S
...

Penal Code section 1202,1"

~

to the probable causative agent of Acquired Immune Deficiency Syndrome (AIDS),

,_

FELONY COMPLAINT ---------

E~e

16

-~--------------

.. ,.

8188381423:

SF [lA,

PAGE

113/31

.\

COUNT 17

. On lOll" n~p.vc~n September

1, 2007 and

September

1, 2003, in the County of Los Angeles, the crime 288(a), a Felony, was
act

of

LEWD ACt- UPoN
i'l:

A CHU.D, in violation

of PENAL CODE SECTION

committed upon and

by P;A..UJu CHAPEL, who dill willfully, unlawfully, and lewdly commit a lewd and lascivious

I'>'ith the body and certain

parts lind members thereof ofl

Ch.iJd 5

I, a child

under the age of

fourteen years, with the intent of arousing, appealing to, and gratifying the 11Ist,passions, and sexual desires (If ttle said defendant and the said child.

"No-neE:'

The wove offense is a serious felony within the meaning ofpenal
to

Code section 1192. 7(G). ,.
at

"NonCE:' Ccmvicti()n of this offense will require
Wil Ifulfai J ure tq' regi ster is a crime." ,,, .
":'-:

register pursuant to Penal Code section 290

seq.

"NOnCE:

Being charged

with this criminal offense can result in mandatory

pre-conviction

HJViAIDS

testing

311d

disdcsun: of the results to a victim and the Chief Medical Officer of die jail or prison facility
pursuant to Penal Cod~ Section 1524.land Health $.nd Saf~ Code section

where you are Incarcerated 12 I Q 5 5 fo IIO\.~... jng a

pro bable

cause hearing

resu j ting

in a court order."

FELONY COMPLAINT

fs!!g! 17

C@;;;e No. PM?'

543

05/17/2012

17;t~

6199361423

SF DA

PAGE

1'3/31

COUNT1S

all or
ccmmhted

between September I, 2007 and September

J. 200&. in the County of Los Angeles, the crime and lewdly commit lewd and laseivieus ACt

of LEWO ACT UPON A CHILD, in violatlon QfPENAL CODn S.ECTIOl\' 2gS(a), a Felony, was

by J1:AUL CHAPEL,

who did willfully, unlawfully,

upon and with fourteen years,

too body
witl)

and certain parts and members th.ereofQ~

Child 5

I. a child under the age of

It

the intent of arcuslng, appealing

to, and gratifying

the IU5t~ PU:-;!QllS, and sexual desires

uftlie !:ala defendant and the said child. n1'.~OTJCE~ The above offense is a serious felony within the: meaning of Penal Code section J 192. 7fc),' "NOTICE: Conviction of this offense will require to register pursuant to Penal Code section 290 et seq. Willful failure to regjlito, jt! a crime." "NOTICE; Being charged with thl$ crimina J offense can result in man datory pre-conviction resting and d isc ~osure of the resu Its to a victi m and the whe r ~ yuu are incarcerated

mv /A IDS

ell lef Med ical Officer of the j ai 1 or pd son fa~ ility

pu rsuaut to Pen al Code S ection 1524. 1and Hc~1th arid Safety Code section

121 ()5 5 fo Ilowl Ii8 i probable cause h caring rlt!lu I ting in a court order."

Page 16

CaGe No, PA071543

FELON''t COMPL4INT

05/17/2~12

17:1~

'8188381423

SF DA

P"GE

2B/31

COUNT 19 On 'Q~~~et'o/ce:n September 1, 2009 and September 1,2010, in the County of Los Angeles, the crime of LEWD ACT UPON A CHJLD, in violation of PENAL CODE SECTION 288(a),
!l

Felony, was

committed by PAJJt CHAPEL, who did willfully, unlawfunv, and lewdly commit a lewd and lascivious act

,upon a~d with tl1e body and certain parts and members thereofo~
of the siid'&fcmdant

Ch.i.1d 6

I, a cblld under the age of

fo II (teen, years" with the intent of arousin g, appeal iI1g to, !II1d gratifY in g the lu st, pas si 0 ns, and sexua I des ireg and the said child. of this offense will require to register pursuent to Penal Code section 290 et set:j. "NOTlffi: "NOTIC~: Th~ above offense is a serious felony within the meaning of Penal Code section 1192.7(c)." Conviction

Willful failure to register is a crime." "KOTTeR: Being charged with this criminal offense can result In mandatory pre-conviction HIV/AIDS testing and disclosure of'thc results to a victim and the Chi"f Medical Offic'cr of the jailor prison facility where yo ~I ar~)11 carcerated pursuant to Penal Corle Secti Oil 1'24.1 and Health and Safety Code secti I))] 12l O.s~ foHowi~g'~ probable cause hearing resulting in a court order."

Page 19

Ca~ No, PA071543

FELO.W COMPLAINT

~

05/17/2812 "

-~-:17:1~
).

F

3188381423

SF DI'!!

PAGE

21/31

COUNT 20 .On Or between September 1, 2QG9 and September of LEWD ACT tJPON A 1, 2IHO, ill the County of Los Angeles:, the crime lewd and lascivious act under the age of

CHlLD, in violation of PE..'iAL CODE SECTION 28&(a), a Felony, was
::I.

cornrnirtcd by PAt:L CHAPEL, who did willfully. unlawfully, and lewdly commit up,on and with rhe body and certain parts and members thereof 0

ChUd 6 ,a. child

fou rteen

YU:'"

with the intent of arousing,

appealing to, and gratlfYing the Just, pass ions, and ~exllElldesires
1192,7(-=),"

, of (he said defendant and the: said child. "NOTlCE.~ T~ above offense is a serious ulony within the meaning of Penal Code netion ":\JO;n¢E; ''NOnCE; Conviction of this offense will require 10 register pursuant
to

Penal Code section 290 et seq, HJV/AIDS

Willful failure ~o !igi!lter is a crime," Being charged with this criminal offense can rC$u)t in mandatory pre-conviction te,Stil1g and disclosure of the Nsults to a vj~im and the Chief Medical Officer of the jailor prison facility whe~e you are incarcerated pursuant 10 Penal Code Section 1524, land Health and Safety Code section 121 055 following a probablt: eause heann g resu lting in
&

court order."

Rev. 90Q·1199 DA case J1~63837

Paae20

CiI§e No. PA071543

FELONY COMPLAINT

t:l18B3B1423:

SF" DA

PAGE

22/31

COUNT 21 On or Qen"'een Scptli1tnber 1, 2009 and S =ptem ber 1, 20 10, in the o f Los ngeles, the crime

or LE\VD ACT

COUll ty

A

UPON A CHILD, in violation ofpE~AL CODE SECTION 2gi(a), a Felony, was

committed by PAuL CHAPEL, whe did willfully, unlawfully, and lewdly commit a lewd and lascivious [let upon and with the body and certain of the- satd defendant "NOTicE: "NOTICE:
\.

parts and members thereof ofl ChUd 6
appealing to, and gratifying

l a child

under the age of

, fourteen years" with the intent of arousing, and ihe said child.

the lust, passions. and sexual desires

The above offense is a serious felony within the meaning ofJlenal Code section 1192.7(.;)," Conviction of thls offense will f~qul;c register pursuant to Penal Code section 29-0et seq, to
10

WillI1-rIfailure

register is a crime." l:lJV/AlDS

"NOTICE: Bei~g charged with this criminal offense can result in mandatory Pf~wnviction

testing and disclosure of the results to a victim and the Chief Med leal Officer of the jailor prison facility where you are inCarcerated pursuant to Penal Code Section 1524. r and Health and Safety Code section 121055 fcilowmg a probable caus€: Marillg resulting in a court order."

C~6e No. PA07154.l

FELONY COMPLAINT --

_-_.

__

..,.,

.._---,

05/17/2EH2

,- "-8188:3131423 1 ;h1;;1

· ..

SF DA

PAGE

23/31

COUNT 22
On oO)e:tw'Irm September 1,2006 and September 1,2009, in the County of Los Ang¢its, the crime of LEWD ACTrJ'PON A CHILD. in violation of PENAL CODE SECTIO::-J 28S(a), a Felony, was
who did wHlfully, unlawfully, and lewdly commit a lewd and laRc1viQtJ5 act

committed by PA1}L CHAPEL,

upon and wi rh th e body and certain parts and members til ereof fourteen years, with tnt> intent of arousing, appealing of the said defendant and the said chHd. "NOTICE:
to, and

ofl ChiLd 71, a child

under the age (If

gratifYing the lust, passions, and sexual desires

The above offense is a serious reloay within the meaning of Penal Code sectlou 1192.7(c)."

"NOTICE~ t:;ol!lI(ctioo of this offense wiJl require to register pursuant to Penal Code section 290 et seq. Willful failure to register is a testing and disclosure

crime."
pre-conviction HIV/AlDS prison facility

"NOT1CE: Baing charged with this criminal offense can resort in mandatory where you are incarcerated

of the results to a victim and the Chief Medic.al Officer of the jailor

pursuant to Penal Code Section 1524.1 and Heal!h and Safety Code section

121055 fr:>lIowing a probable cause hearing resulting in a court order."

Page

22

. __

~

._......;,C~as",e~No"".,-,P_!:,A".9 .... 71,,_,54=3

FELONYCOMPUlNT

~---.[~

85/17/2612

8188381423

SF DA

PAGE

24/3:

coc-rr
On
committed
upon

23

or Oe'fW'eet1 eptember S
by PAUL CHAPEL,

1,2009 and September l , 2!)1(1. in the
willfully, unlawfuny,

County

of L05 Angeles, the crime

of LEWD ACT UPON A CHILD, In vlola1iOllof PENAL CODE SECTION 288{a), a Felony, was whc did
and lewdly commit a lewd and lascivious act

and

with the

body and certain

parts and members

thereof

ofl

ChUrl

a I a child

under the age of and sexual desires

fourteen years, with the intent of arousing, appealing

to, and gratifying

tb~ lust, passions,

. of the -said defendant and the said child,
. ''NO!JCE: The' above offense

il) a serious felony within 1b.~meaning of'Penal Code section 1192.7(1::)," seq,

, ''NOT1CE,: ~l;1nvrction of this offense will require to register pursuant to Penal Code section 290.t Willful fl'lill,1re
"NOTICE:

ts. re:gister

iii a crime."
pre-conviction HlV/AIDS Officer

Being charged with this criminal offense can result in mandatory

testing and ~isclL7811reof the results to a victim and the Chief Medical where you arc

of the

jail or prison facility

mcarcerated

121 05S'followlng a probable

..

pursuant

to

Penal Code

Section in a

1524. J and Health and Safety

Code

section

cause hearing resulting

court order."

"

Psge23

em N5!.. P.l\011§43-

FELONY COMPLAINT

8189381<123

SF DA,

PAGE

25/:1

COUNT 24
011 or ~=en committed September I, .2009 and September

1,201 G, in the County of Los Angeles, the crime

of LEWD ACT UPON A CHILD, in violation of PENAL CODE. SECTION 28S(a), a Peiony, was
by PAUL CHAPEL, who did willfully, urllawfully, and lewdly commit a I~cl and Iasc;r.:iotls act upon and with ~e body and certain parts and members thereof of of the said defendant and the said ch.lld. "NonCF.: The-above offense is a serious felony within the meaning of Penal Code section lJ92.7(c)."
to Penal Cede flection 290 et seq.

I ChUrl 9

I, a child

under the age of

fourteen years, with the intent of arousing, appealing to, and gratizying the lust, passions, and sexual desires

"NOnCE; Conviction cf this offense will require to register pur,utmt
Wil_lfnI failure to register is a crime."

"NOTICE: Being charged with this crimina] otrense can result in mandatory

pre-conviction

HJV/J\.IDS

t¢:sting and disclosure of the results te a victim and the Ch_tflfMedicaJ Officer of the jail or prison facility where you are inC8]'cerated pursuant to Pena] Code Section 1524, r and Health and Safety Code section
t 21055 following

a probable cause hearing resujting in a court order,

II

'.

c@~ NQ, PA071~43

FELONY COMPLAINT

85/17/2B12

17:13

8188:381423

SF DA.

PAGE

2'D/,"

COUN12j
.On

or !;Iirt\veen September 1, 2QlO and September 1,201 J ,11'1 the County of LOf: Angeles, the clime YPON A CHILD, in violation ofPENAJ_ CODE SECTION 2!l8(a), a Felony, was

of LEWD
conunitted

ACT

byJ'AUL CHAPEL, who did wiHfu!ly. unlawfully, and lewdly commit a lewd and lascivious act

fourteen years, with the intent of arousing, appealing to, and gratifying ilIa lust, passlons, and sexual desires nfthe said defendant and the s!ljd child. "'NOnCE; The above offense is
"
tl

serious felony within the nteanillg of Penal Code section ll91-7(c)."
et

":",JOTICE: COMjction of this offense will requite to register pursuant to Penal Code section 290

seq.

\Vii Ifulfaiiur~ to regrster is Il. crime,

II

"NOnCE; Being charged with this criminal offense can result in mandatory pre-cooviction HIV/AIDS testing and disclosure of the results to a victim and the Chief Medical Officer of the jailor prison facility where you are incarcerated pursuant to Penal Code Section 1524. rand Health and Safety Code section 121055 f~lI(lwj"g a probable cause hearing resulting 111 court ower." a

FELONY COMJ>LA1NT

case No, PA071543.

8188391423

PAGE

27/3

COUNT 26
an or between ofT,EWD,ACT:UPON cornmnred

September

I, :2f109and September
of PE~AL

1, 2010, ifl the County of Los Angeles. the crime
CODE

A CfULD, in violation

SECTION

288(a),

a Felony, was a lewd And lascivious
the

by

PAUL CflAFEL,

who did willfully,

unlawfully.

and lewdly commit

act

upon and with. the body and certain part! and members thereof ofl fourt~~n years, with the Int~t of the said defendant and the said child, "NOTICE:
"NOTICE; The ;;tbo~ offense is Conviction of this

Child
the

11

!, a I;hild under
passions,

age of

of'arousing, appealing to, and gnrtii)'ing

Just,

and l>nual desires

a. serious

felony within the require

meanmg

of f't;nal Code section

1192.7(c)."

offense will
II

to

register pursuant to Penal Code scctj(l.n 290 et seq.

Willful failure to.register "NOTICE; Being charged

is a crime,

with

this; criminal offense can result in mandatory to a victim

pre-conviction

HlY/AIDS

testing and disclosure of the whe~e you

are it.carcerated

results

and

the Chief Medical

Offlcer of the jail or prison facl1ity
Health and Safety Code s~c-tiQn

pursuant

to Penal Code

Section

}';24.land

.J 21 D55. following a probable cause hearing resulting il'l a court order."

eag,e 26

COlse No. PA071543

FELONY COMPLAINT

r-

-.B5/17!2B12 17:13 8188391423
SF" DA

PAGE

2B/::


Of)

COUNT ').7

or Ilciween

September

J, 2010 and September
it)

L .2011, in the County of Las Angeles, die crime and lewdly commit a lewd and lascivious

of LEWD AC~ UPON A CHlLD, committed by PAUL CHAPEL,

violation of pENAL CODE SECnON 2gS(a), a Felony, was
act

who did willfully, unlawfully,

upon and with t"'e body and certain parts and members thereof o~ Chj]d 12 ~ a child under the age of fourteen years wi~l the intent of arousing, appealing to, and gratlzying the lust, passions, and sexual de~iles of the seid defendant and the said child,

"NoncE: : The a~ovc offense is a serious klony within the meaning ofl'erllll Code section 1192.7(~}.·
"NOTlCE: C0~"iction ofdlis offense will require to register pmsus.nt WiJlful failure tel register is testing and disclosure
11 crime.'

1:(1 Pcna!

Code section 290

et

seq.

"NOTICE: Heing charged with this criminal offense can result in mandatary pre-conviction .B1VJAIDS of the results to a victim and the ChiefMcdjeaj Officer of the jailor prison facility where you ere incarcerated pursuant to Penal Code Section 1524.1 and Health and Safety Code section 121055 following a probable causebcarmg resulting in . ~

a court order.'

PAge: 27

Case

Mo- PA011S4A

FELONY COMPLAINT

·05!17/2B12

~7:13

8198381423

PAGE

29/.:;

COUNT 28

On or between September 1.2009 atld September 1, 2{1l0, in the County of Los Ange!es,lht: crime
of

LEWP ACT CP01\T A C,HILD, in violation

of PENAL CODE

SECTION

238(a),

a. Felony, ~,a child

was

cornmiued by PA UL CHAPEL, who djd willfully, i..mJa.wfu!ly, and lewdly commit a lewd and lascivious act
upon and with fue body and certain parts and members thereof

ofl

Child 13

under 'the

age

of fourteen years, with the intent of arousing, appealing to, and gratifying the lust, passions, and sexual desires of the said defendant and the said child . . "NOTlCB~ The above offens6 is a serious felony within the meaning of "PenalCode section 1192.7(c):'

.

"NOT1CE; Conviction of this offense will req1.rire to register pUrsuant to Penal Code section 290
\Villful failu~ ttJi-egi.'iter is a crime." . . "NOTTCE: ~eing charged with this criminal offense can resu It in mandatory

et

seq.

pre-conviction HTVI ATDS
Or

testing and disclosure oftbe results to a victim and the Chief Medical Officer of the jail

prison facility

where you are incarcerated pursuant
12.1 055 following
1I

to

Penal

Code

Section 1524_1and Health

and Safety Code section

probable

C311!le

hearing resulting in a. court order."

I, is further alleged, withi. the mcantng of P.M.H. CHAPEL, ~4. 25,26.27
"i;I': ~ ,

,,,,,,I Cod, ",,60n

as to coun1(s)

1,2,3,4,5,6,7,8,9,

10, 11, 12,13, 14, 15, 16, 17,18, ]9, ;W, 21,22,23, apply: multiple victims.

~.:.~;;,~£:2~ ('D..t.

and 28 rhst the followlng clrcumstances

PI.EASE TAKE NOTICE PURSUANT TO EVIDENCE CODE SECTIONS 1108 AND J1{l9111 A. T PRIOR
1NCIDE~'TS OF SEXUAL ASSAULT AND OR DOMESTIC VJOLENCE MAY BE USED IN THE PROSECUTION OF rr-D'.s DEFENDANT- FURTHER TAKE NOTICE 11fE ?EOPLE MAY PROCEED

P1.;~_SUANTTO"tVlt)F!NCE CODE. SECT[ON 1101.

pageZS

Case Nq, PAQ715~

FELONY COMPLAINT

f

--

,

r~ ,

05/17/2B12

~7~r3

8188381423

SF DA

P~E

3H/::

..
NOtICE:Ca'lViction Df this offense will requir~ the defendant to p'rovid~ DNA ~ample-..,and print the lIamples impre'li!lioRS p!Jl'suant 10 PC!nalCode sections 296 ud 296.1. Willful refusal toprevsde
flQd

imJlTfistoD:i .is a ~rime.
The People of the: State of CalifOl'llia fnwntf to present evlden('.e and seek jurytindinWl all applicaf)Je cirCllnutam;:es in aggravation, pursuant to Penal Code sectlen ll7O(b) and
ll.

'NOTICE: re~rdtng

OlRningham '~OTI~t;

Califomi4 (l00'7) 549 U,S. :276. within tbe mt:aoiog

A,Suspected ClUld Abh8e Report (SCAR) may have been gcull'atd

of Penal COOe §§ 11166 and 11 HiS in\'OMng the du.,g~ aJleged in this compla.int. Dtsserllinatinn {If a SeA\{ is Umi~d lIy Penal Code §§ 11167 and 11167.5 and a wurt order is ~quired for fun disdosu·r-e of the contents of a SCAR NOTICE: Any aUegatioli making a defend&hl ineligible to serve a !!tat~ pril'lon sentence itt tbc

coun l)' ja.n sbaU not be su b,ject to dismissal pu

nua.,.t to Penal

Code

§ 1385.

TDECLARE UNDER PENALTY

OF' PERJURY

THAT THE FOREGOING IS TRUE AND CORREct

A:"{Dn1.o\.T nus COMPLAINT, CAse NUMBER PA071543, CONSISTS OF 28' COt.'NT(S).

Executed

itT:

SAN FERNANDO,

County of Los Angeles, on May] 7,2012. RACHEL SAAVEDRA. DECLARANT AND COMPLAINANT

.~~I'

•••••••

tl

' I~.'."""

'r'

-r·

~- .""

__ """.'

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Or •••••••••

p", •• r

,

, I~"

."."

__ "

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-- ---,

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•• 1.'

•• •• '4

' •• r"'

.. , ••

STEVECOOLEY,

DISTR1CT ATTORNEY

AGE1'.'g_'(: LAPD" JUVENiLE DR NO.: 1116085151

MQ: RACHEL SAA VEDR.<\ I.t!1iQ.: 3.2S03et!m!E: ~_rp__B; CAB P,llliLIM, 1TME.EST-:

(213) 486-0;570

CUe Np.PAQZ;f543

FELONY

COMPJ..AINT

'«---

--05/17/21)12

----17:' 13 ,,~ 8188381423 SF DA PAGE 3113

f.
J

DEFEl~Iu~m CHA.PEL, PAl;,Ic-

_CII NQ,

OOB

BOOKING
NQ.

008746342

5113/J961.

BAIL MCOM'P

CUSTODY R'TN DATE

$3,400,000

provide cliscovffY.to the People as required by Pcna' Code S~OIi, 1054.3.

Pursuant to Penal C<)dc Section I054,S(b), the People 'Ire hereby informally requesting that defense counsel

Case No, PA071543

FELONY COMPLAINT