SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO RANCHO CUCAMONGA DISTRICT. Defendant COUNT 1
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1 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO RANCHO CUCAMONGA DISTRICT THE PEOPLE OF THE STATE OF CALIFORNIA, Plaintiff vs. Gary Randell Schan Defendant COURT CASE NO. FWV FIRST AMENDED FELONY COMPLAINT DA CASE NO The undersigned is informed and believes that: COUNT 1 On or about January 1, 2003 through December 31, 2003, in the above named judicial district, the crime of LEWD ACT UPON A CHILD, in violation of PENAL CODE SECTION 288(a, a lewd and lascivious act upon and with the body and certain parts and members thereof of Jane gratifying the lust, passions, and sexual desires of the said defendant(s and the said child. Report (SCAR may have been generated in this case. Penal Code Section and Page 1
2 "NOTICE: The above offense is a serious felony within the meaning of Penal Code section (c and a violent felony within the meaning of Penal Code section 667.5(c." Syndrome (AIDS. Penal Code section " It is further alleged, within the meaning of Penal Code section (b and (e, as to <DCS>, as to count(s 1, 2, 3, 4, 5, 6 that the following circumstances apply: multiple victims. COUNT 2 On or about January 1, 2004 through December 31, 2004, in the above named judicial district, the crime of LEWD ACT UPON A CHILD, in violation of PENAL CODE SECTION 288(a, a lewd and lascivious act upon and with the body and certain parts and members thereof of Jane gratifying the lust, passions, and sexual desires of the said defendant(s and the said child. Page 2
3 Report (SCAR may have been generated in this case. Penal Code Section and "NOTICE: The above offense is a serious felony within the meaning of Penal Code section (c and a violent felony within the meaning of Penal Code section 667.5(c." Syndrome (AIDS. Penal Code section " It is further alleged, within the meaning of Penal Code section (b and (e, as to <DCS>, as to count(s 1, 2, 3, 4, 5, 6 that the following circumstances apply: multiple victims. COUNT 3 Page 3
4 On or about January 1, 2005 through December 31, 2005, in the above named judicial district, the crime of LEWD ACT UPON A CHILD, in violation of PENAL CODE SECTION 288(a, a lewd and lascivious act upon and with the body and certain parts and members thereof of Jane gratifying the lust, passions, and sexual desires of the said defendant(s and the said child. Report (SCAR may have been generated in this case. Penal Code Section and "NOTICE: The above offense is a serious felony within the meaning of Penal Code section (c and a violent felony within the meaning of Penal Code section 667.5(c." Page 4
5 Syndrome (AIDS. Penal Code section " It is further alleged, within the meaning of Penal Code section (b and (e, as to <DCS>, as to count(s 1, 2, 3, 4, 5, 6 that the following circumstances apply: multiple victims. COUNT 4 On or about January 1, 2003 through December 31, 2003, in the above named judicial district, the crime of LEWD ACT UPON A CHILD, in violation of PENAL CODE SECTION 288(a, a lewd and lascivious act upon and with the body and certain parts and members thereof of John gratifying the lust, passions, and sexual desires of the said defendant(s and the said child. Report (SCAR may have been generated in this case. Penal Code Section and Page 5
6 "NOTICE: The above offense is a serious felony within the meaning of Penal Code section (c and a violent felony within the meaning of Penal Code section 667.5(c." Syndrome (AIDS. Penal Code section " It is further alleged, within the meaning of Penal Code section (b and (e, as to <DCS>, as to count(s 1, 2, 3, 4, 5, 6 that the following circumstances apply: multiple victims. COUNT 5 On or about January 1, 2004 through December 31, 2004, in the above named judicial district, the crime of LEWD ACT UPON A CHILD, in violation of PENAL CODE SECTION 288(a, a lewd and lascivious act upon and with the body and certain parts and members thereof of John gratifying the lust, passions, and sexual desires of the said defendant(s and the said child. Page 6
7 Report (SCAR may have been generated in this case. Penal Code Section and "NOTICE: The above offense is a serious felony within the meaning of Penal Code section (c and a violent felony within the meaning of Penal Code section 667.5(c." Syndrome (AIDS. Penal Code section " It is further alleged, within the meaning of Penal Code section (b and (e, as to <DCS>, as to count(s 1, 2, 3, 4, 5, 6 that the following circumstances apply: multiple victims. COUNT 6 On or about January 1, 2005 through March 14, 2005, in the above named judicial district, the crime of LEWD ACT UPON A CHILD, in violation of PENAL CODE SECTION 288(a, a felony, was committed by Gary Randell Schan, who did willfully, unlawfully, and lewdly commit a lewd and lascivious act upon and with the body and certain parts and members thereof of John Doe, a child Page 7
8 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(s and the said child. Report (SCAR may have been generated in this case. Penal Code Section and "NOTICE: The above offense is a serious felony within the meaning of Penal Code section (c and a violent felony within the meaning of Penal Code section 667.5(c." Syndrome (AIDS. Penal Code section " It is further alleged, within the meaning of Penal Code section (b and (e, as to <DCS>, as to count(s 1, 2, 3, 4, 5, 6 that the following circumstances apply: multiple victims. Page 8
9 * * * * * NOTICE TO DEFENDANT AND DEFENDANT S ATTORNEY Pursuant to Penal Code Sections (b, the People are hereby informally requesting that defense counsel provide discovery to the People as required by Penal Code Section NOTICE TO ATTORNEY The materials accompanying this notice may include information about witnesses. If so, these materials are disclosed to you pursuant to Penal Code section which provides: "No attorney may disclose or permit to be disclosed to a defendant the address or telephone number of a victim or witness whose name is disclosed to the attorney pursuant to subdivision (a of Section unless specifically permitted to do so by the court after a hearing and a showing of good cause." I DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT AND THAT THIS COMPLAINT CONSISTS OF 6 COUNT(S. Executed at Rancho Cucamonga, California, on November 6, F Ramos F Ramos DECLARANT AND COMPLAINANT Agency: Ontario Police Department Prelim Est. 00:00 Defendant Gary Randell Schan Birth Date 09/24/1950 Booking No CII No. H NCIC Page 9
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