SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT. Defendant
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1 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO SAN BERNARDINO DISTRICT THE PEOPLE OF THE STATE OF CALIFORNIA, vs. Plaintiff William Jason Jones, Emeshia Delayshon Montgomery, aka Emeshia Delayshon Montgomery Woods Defendant COURT CASE NO FELONY COMPLAINT DA CASE NO The undersigned is informed and believes that: COUNT 1 On or about June 3, 2013, in the above named judicial district, the crime of KIDNAPPING, in violation of PENAL CODE SECTION 207(a, a felony, was committed by William Jason Jones, who did unlawfully, forcibly and by instilling fear, steal, take, hold, detain or arrest Roy Jimenez in San Bernardino County, California, and did take the said Roy Jimenez into another country, state, county and another part of San Bernardino County. "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." It is further alleged that pursuant to Penal Code section 1170(h(3 defendant(s William defendant(s William Jason Jones has a prior serious or violent felony conviction; Page 1
2 defendant(s William Jason Jones has been convicted of a crime with a Penal Code section the crime is not punishable pursuant to Penal Code section 1170(h(3. COUNT 2 On or about June 3, 2013, in the above named judicial district, the crime of TORTURE, in violation of PENAL CODE SECTION 206, a felony, was committed by William Jason Jones, who did unlawfully and with the intent to cause cruel and extreme pain and suffering for the purpose of revenge, extortion, persuasion and for a sadistic purpose, inflict great bodily injury, as defined in Penal Code section , upon Roy Jimenez. It is further alleged that pursuant to Penal Code section 1170(h(3 defendant(s William defendant(s William Jason Jones has a prior serious or violent felony conviction; defendant(s William Jason Jones has been convicted of a crime with a Penal Code section the crime is not punishable pursuant to Penal Code section 1170(h(3. COUNT 3 On or about June 3, 2013, in the above named judicial district, the crime of FALSE IMPRISONMENT BY VIOLENCE, in violation of PENAL CODE SECTION 236, a felony, was committed by William Jason Jones, who did unlawfully violate the personal liberty of Roy Jimenez, said violation being effected by violence, menace, fraud, and deceit. It is further alleged that pursuant to Penal Code section 1170(h(3 defendant(s William Page 2
3 defendant(s William Jason Jones has a prior serious or violent felony conviction; defendant(s William Jason Jones has been convicted of a crime with a Penal Code section the crime is not punishable pursuant to Penal Code section 1170(h(3. COUNT 4 On or about June 3, 2013, in the above named judicial district, the crime of ASSAULT BY MEANS LIKELY TO PRODUCE GREAT BODILY INJURY, in violation of PENAL CODE SECTION 245(a(4, a felony, was committed by William Jason Jones, who did willfully and unlawfully commit an assault on Roy Jimenez by means of force likely to produce great bodily injury. It is further alleged that pursuant to Penal Code section 1170(h(3 defendant(s William defendant(s William Jason Jones has a prior serious or violent felony conviction; defendant(s William Jason Jones has been convicted of a crime with a Penal Code section the crime is not punishable pursuant to Penal Code section 1170(h(3. COUNT 5 On or about June 3, 2013, in the above named judicial district, the crime of ACCESSORY AFTER THE FACT-(KNOWLEDGE OF CRIME, in violation of PENAL CODE SECTION 32, a felony, was committed by Emeshia Delayshon Montgomery, who unlawfully, having knowledge that the crimes of Kidnapping, Torture, False Imprisonment by Violence and Assault by Mean Likely to Cause Great Bodily Injury, a felony, in violation of Sections 207(a, 206, 236 and 245(a(4 of the Page 3
4 Penal Code of the State of California had been committed by William Jones, did harbor, conceal, and aid said William Jones, with the intent that he/she might avoid and escape from arrest, trial, conviction, and punishment for said felony. It is further alleged as to count(s 1, 2, 3, 4 pursuant to Penal Code section 667.5(b that the defendant(s William Jason Jones, has suffered the following prior conviction(s: Court Case Code/Statute Conv Date County State Court Type FSB VC /07/2001 San Bernardino CA Superior FSB HS11377(a 08/27/2004 San Bernardino CA Superior FSB PC459 05/29/2008 San Bernardino CA Superior FSB PC476 10/03/2011 San Bernardino CA Superior FSB HS /15/2007 San Bernardino CA Superior and that a term was served as described in Penal Code section for said offense(s, and that the defendant(s did not remain free of prison custody for, and did commit an offense resulting in a felony conviction during, a period of five years subsequent to the conclusion of said term. * * * * * 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." Page 4
5 I DECLARE UNDER PENALTY OF PERJURY THAT THE FOREGOING IS TRUE AND CORRECT AND THAT THIS COMPLAINT CONSISTS OF 5 COUNT(S. Executed at San Bernardino, California, on June 5, R. Brown, DDA R. Brown, DDA DECLARANT AND COMPLAINANT Agency: ABC Cerritos Prelim Est. 00:00 Defendant William Jason Jones Emeshia Delayshon Montgomery Birth Date 12/16/ /29/1970 Booking No. CII No. A A NCIC Page 5
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