Jaime Ramos Pablo Ruvalcaba Indictment

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IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTY OF SAN JOAQUIN
The People of the State of California,
Plaintiff,
v.
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JAIME RAMOS
PABLO RUVALCABA
) D.A. # GJ-2014-4085296
)
) INDICTMENT
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) CR No. SP14-26068
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Defendant(s).
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The Grand Jury of the County of San Joaquin, State of California,

accuses the Defendant(s) of committing, in the County of San
Joaquin, State of California, before the finding of this
Indictment, the following crime(s):
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COUNT 1: WILLFUL, DELIBERATE, PREMEDITATED MURDER PC.187(A)<F22
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On or about July 16, 2014, in the County of San Joaquin,
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California, JAIME RAMOS AND PABLO RUVALCABA, did commit the crime
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of WILLFUL, DELIBERATE, PREMEDITATED MURDER, in violation of

Section 187(a) of the Penal Code, a FELONY, who at the time and
place last aforesaid did willfully, unlawfully, and with malice
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aforethought murder MISTY HOLT-SINGH a human being. It is further
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alleged that the aforesaid murder was committed willfully,

deliberately and with premeditation within the meaning of Penal
Code Section 189 and is a serious felony pursuant to Penal Code
Section 1192.7(c).
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1.
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SPECIAL CIRCUMSTANCE: MULTIPLE MURDERS PC.190.2(A)(3)

It is further alleged that the offense charged in counts ONE, are a
special circumstance, within the meaning of Penal Code Section
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190.2(a)(3).
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SPECIAL CIRCUMSTANCE: ROBBERY PC.190.2(A)(17)(A)
It is further alleged that the murder of MISTY HOLT-SINGH was
COMMITTED by defendant, JAIME RAMOS , while the said defendant
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ENGAGED IN THE COMMISSION OF the crime of ROBBERY, within the

meaning of Penal Code Section 190.2(a)(17)(a).
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SPECIAL CIRCUMSTANCE: KIDNAPPING PC.190.2(A)(17)(B)
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committed by defendant, JAIME RAMOS , while the said defendant was
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engaged in the commission of the crime of Kidnapping in violation
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of Penal Code Section 207 and 209.
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SPECIAL CIRCUMSTANCE: BURGLARY MURDER PC.190.2(A)(17)(G)
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ENGAGED IN THE COMMISSION OF
the crime of BURGLARY, within the
meaning of Penal Code Section 190.2(a)(17)(g).
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2.
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SPECIAL CIRCUMSTANCE: MURDER COMMITTED CRIMINAL STREET GANG

PC.190.2(A)(22)
It is further alleged, pursuant to Penal Code Section 190.2(a)(22),
that the defendant, JAIME RAMOS , intentionally killed MISTY HOLT-
SINGH while the defendant was an active participant in a criminal
street gang, and that the murder was carried out to further the
activities of the criminal street gang.
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PRINCIPAL'S INTENTIONAL DISCHARGE OF A FIREARM, GBI-GANG CASE

PC.12022.53(D)(E)(1)
As to defendant JAIME RAMOS it is further alleged that in the
commission of the foregoing offense, a principal intentionally and
personally discharged a firearm, to wit: SEMI-AUTOMATIC FIREARM,
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and proximately caused great bodily injury as defined in Penal Code

Section 12022.7, or death, to a person other than an accomplice, to
wit: MISTY HOLT-SINGH within the meaning of Sections 12022.53(d)
and (e)(1) (and 12022.53(c) and 12022.53(b) of the Penal Code.
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CRIMINAL STREET GANG ACTIVITY PC.186.22(B)(1)

It is further alleged that pursuant to Penal Code Section
186.22(b)(1) that the above offense was committed by JAIME RAMOS
for the benefit of, at the direction of, or in association with a
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criminal street gang, and with the specific intent to promote,

further, or assist in criminal conduct by gang members.
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3.
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It is further alleged that the offense charged in counts ONE are a
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190.2(a)(3).
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COMMITTED by defendant, PABLO RUVALCABA , while the said defendant
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AN ACCOMPLICE IN THE COMMISSION OF
the crime of ROBBERY,
within the meaning of Penal Code Section 190.2(a)(17)(a).
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committed by defendant, PABLO RUVALCABA , while the said defendant
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was engaged in the commission of the crime of Kidnapping in
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violation of Penal Code Section 207 and 209.
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the crime of
BURGLARY, within the meaning of Penal Code Section 190.2(a)(17)(g).
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4.
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PC.190.2(A)(22)
that the defendant, PABLO RUVALCABA , intentionally killed MISTY
HOLT-SINGH while the defendant was an active participant in a
criminal street gang, and that the murder was carried out to
further the activities of the criminal street gang.
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PC.12022.53(D)(E)(1)
As to defendant PABLO RUVALCABA it is further alleged that in the
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186.22(b)(1) that the above offense was committed by PABLO
RUVALCABA for the benefit of, at the direction of, or in
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association with a criminal street gang, and with the specific

intent to promote, further, or assist in criminal conduct by gang
members.
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5.
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:
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aforethought murder ALEX MARTINEZ a human being. It is further
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Section 1192.7(c).
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It is further alleged that the offense charged in counts TWO, are a
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190.2(a)(3).
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It is further alleged that the murder of ALEX MARTINEZ was

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the crime of BURGLARY,
within the meaning of Penal Code Section 190.2(a)(17)(g).
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PC.190.2(A)(22)
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that the defendant, JAIME RAMOS , intentionally killed ALEX
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MARTINEZ while the defendant was an active participant in a
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PC.12022.53(D)(E)(1)
personally discharged a firearm, to wit: SEMI- AUTOMATIC FIREARM,
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wit: ALEX MARTINEZ within the meaning of Sections 12022.53(d) and
(e)(1) (and 12022.53(c) and 12022.53(b) of the Penal Code.
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It is further alleged that the offense charged in counts TWO are a
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190.2(a)(3).
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the crime of
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PC.190.2(A)(22)
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that the defendant, PABLO RUVALCABA , intentionally killed ALEX

MARTINEZ while the defendant was an active participant in a
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PC.12022.53(D)(E)(1)
personally discharged a firearm, to wit: SEMI-AUTOMATIC and
proximately caused great bodily injury as defined in Penal Code
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wit: ALEX MARTINEZ within the meaning of Sections 12022.53(d) and
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members.
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aforethought murder GILBERT RENTERIA a human being. It is further
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Section 1192.7(c).
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It is further alleged that the offense charged in counts THREE, are

a special circumstance, within the meaning of Penal Code Section
190.2(a)(3).
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It is further alleged that the murder of GILBERT RENTERIA was
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the crime of BURGLARY,
within the meaning of Penal Code Section 190.2(a)(17)(g).
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PC.190.2(A)(22)
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that the defendant, JAIME RAMOS , intentionally killed GILBERT

RENTERIA while the defendant was an active participant in a
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PC.12022.53(D)(E)(1)
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personally discharged a firearm, to wit: SEMI-AUTOMATIC FIREARM and
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wit: GILBERT RENTERIA within the meaning of Sections 12022.53(d)
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It is further alleged that the offense charged in counts THREE are

a special circumstance, within the meaning of Penal Code Section
190.2(a)(3).
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COMMITTED
by defendant, PABLO RUVALCABA , while the said defendant
the crime of
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PC.190.2(A)(22)
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that the defendant, PABLO RUVALCABA , intentionally killed GILBERT

RENTERIA while the defendant was an active participant in a
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PC.12022.53(D)(E)(1)
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wit: GILBERT RENTERIA within the meaning of Sections 12022.53(d)
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members.
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COUNT 4: ROBBERY PC.211
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of FIRST DEGREE ROBBERY, in violation of Section 211 of the Penal
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Code, a FELONY, who at the time and place last aforesaid, did
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willfully, unlawfully, and by means of force and fear take personal

property from the person, possession, and immediate presence of
BANK OF THE WEST. It is further alleged that the above offense is a
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serious felony within the meaning of Penal Code Section
1192.7(c)(19).
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PC.12022.53(D)(E)(1)
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wit: BANK OF THE WEST, within the meaning of Sections 12022.53(d)

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USE OF FIREARM IN COMMISSION OF FELONY PC.12022.5(A)<F1
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It is further alleged that in the commission and attempted
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commission of the above offense, the said defendant JAIME RAMOS
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personally used firearm(s), within the meaning of Penal Code

Section 1203.06(a)(1) and 12022.5(a) and also causing the above to
become a serious felony pursuant to Penal Code Section
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1192.7(c)(8).
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16.
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PC.12022.53(D)(E)(1)
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wit: BANK OF THE WEST within the meaning of Sections 12022.53(d)

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members.
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COUNT 5: KIDNAPPING TO COMMIT ROBBERY,RAPE,SODOMY, ETC. PC.209(B)(1)

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of KIDNAPPING TO COMMIT ANOTHER CRIME, in violation of Section

209(b)(1) of the Penal Code, a FELONY, who at the time and place
last aforesaid, did willfully and unlawfully kidnap and carry away
KELLY HUBER to commit ROBBERY. It is further alleged that the above
offense is a serious FELONY within the meaning of Penal Code
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Section 1192.7(c)(20).
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PC.12022.53(D)(E)(1)
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wit: KELLY HUBER within the meaning of Sections 12022.53(d) and
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1192.7(c)(8).
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PC.12022.53(D)(E)(1)
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members.
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COUNT 6: ATTEMPTED MURDER:PREMEDITATED PC.664/187(A)
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of ATTEMPTED WILLFUL, DELIBERATE, PREMEDITATED MURDER, in violation
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of Section 664/187(a) of the Penal Code, a FELONY, who at the time
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and place last aforesaid, did willfully, unlawfully, deliberately,

with premeditation and malice aforethought, attempt to murder,
KELLY HUBER A HUMAN BEING.
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PC.12022.53(D)(E)(1)
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PC.12022.53(D)(E)(1)
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personally discharged a firearm, to wit: SEMI-AUTOMATIC HANDGUN,
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members.
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COUNT 7: CARJACKING PC.215(A)
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of CARJACKING, in violation of Section 215(a) of the Penal Code, a
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FELONY, who at the time and place last aforesaid, did unlawfully
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take a motor vehicle in the possession of KELLY HUBER from his/her
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person and immediate presence and from the person and immediate
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presence of a passenger of said motor vehicle, against the will and
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with the intent to permanently and temporarily deprive the person

in possession of the motor vehicle of the possession, and
accomplished by means of force and fear. "NOTICE: The above offense
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is a serious felony within the meaning of Penal Code Section
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1192.7(c) and a violent felony within the meaning of Penal Code

section 667.5(c)". "NOTICE: Conviction of this offense will require
you to provide specimens and samples pursuant to Penal Code section
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296. Willful refusal to provide the specimens and samples is a
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crime".
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22.
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PC.12022.53(D)(E)(1)
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1192.7(c)(8).
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PC.12022.53(D)(E)(1)
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members.
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STEPHANIE KOUSSAYA to commit ROBBERY. It is further alleged that
the above offense is a serious FELONY within the meaning of Penal
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Code Section 1192.7(c)(20).
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PC.12022.53(D)(E)(1)
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wit: STEPHANIE KOUSSAYA within the meaning of Sections 12022.53(d)
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1192.7(c)(8).
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PC.12022.53(D)(E)(1)
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wit: STEPHANIE KOUSSAYA within the meaning of Sections 12022.53(d)
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members.
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MISTY HOLT-SINGH to commit ROBBERY. It is further alleged that the
above offense is a serious FELONY within the meaning of Penal Code
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Section 1192.7(c)(20).
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PC.12022.53(D)(E)(1)
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1192.7(c)(8).
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PC.12022.53(D)(E)(1)
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members.
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COUNT 10: ATTEMPTED MURDER OF A PEACE OFFICER PC.664/187(A)<F25A
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of ATTEMPTED MURDER OF A PEACE OFFICER, in violation of Section
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664/187(a) of the Penal Code, a FELONY, who at the time and place
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aforesaid, did unlawfully attempt to murder OFFICER D. EGAN #1392,
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who was a peace officer/firefighter engaged in the performance of
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duty and this was known, and reasonably should have been known by
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the defendant.
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PRINCIPAL'S DISCHARGE OF FIREARM - GANG PC.12022.53(C)(E)(1)

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personally discharged a firearm, to-wit: SEMI-AUTOMATIC FIREARM
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personally discharged a firearm, to-wit: SEMI-AUTOMATIC FIREARM.
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members.
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aforesaid, did unlawfully attempt to murder OFFICER D.SANDOVAL
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#1560, who was a peace officer/firefighter engaged in the
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performance of duty and this was known, and reasonably should have
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been known by the defendant.
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members.
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aforesaid, did unlawfully attempt to murder OFFICER J.ZAVALA #1653,
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the defendant.
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members.
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aforesaid, did unlawfully attempt to murder OFFICER S.MCPHERSON

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members.
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aforesaid, did unlawfully attempt to murder OFFICER A. ADAMS #2426
, who was a peace officer/firefighter engaged in the performance of
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the defendant.
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members.
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aforesaid, did unlawfully attempt to murder OFFICER H. SENSABAUGH
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members.
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aforesaid, did unlawfully attempt to murder OFFICER N. HANCE #2422,

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the defendant.
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members.
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California, JAIME RAMOS PABLO RUVALCABA, did commit the crime of
ATTEMPTED MURDER OF A PEACE OFFICER, in violation of Section
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aforesaid, did unlawfully attempt to murder OFFICER E. BERGWERFF
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members.
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aforesaid, did unlawfully attempt to murder OFFICER J. SWAN #1724,
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the defendant.
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members.
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aforesaid, did unlawfully attempt to murder OFFICER T. VALONE
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members.
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aforesaid, did unlawfully attempt to murder OFFICER P. MAYER #1999,
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the defendant.
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members.
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aforesaid, did unlawfully attempt to murder OFFICER G. GUERRERO

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members.
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aforesaid, did unlawfully attempt to murder OFFICER M. SERNA #2097,
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the defendant.
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members.
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California, JAIME RAMOS AND PABLO RUVALCABA , did commit the crime
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aforesaid, did unlawfully attempt to murder OFFICER S. VEN #1472,
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the defendant.
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5
6
7
8

9
10
11
12
13

14
15
16

17
18
19
20
21
22
23
24
25
26
27
28
51.
members.
3
4
5
6

7
8
9
10
11
12
13
14
15
16
aforesaid, did unlawfully attempt to murder OFFICER S. KONOSKE

17
18
19
20
21
22
23
24
25
26
27
28

52.
4
5
6
7
10
11
12
13

14
15
16
17
18

members.
19
20
21
22
23
24
25
26
27
28
53.
1
2
3

4
5
6
7

aforesaid, did unlawfully attempt to murder OFFICER P. FREER #2576,
10
the defendant.
11
12
13

14
15
16

17
18
19
20
21
22
23

24
25
26
27
28
54.
1
2
3

4
5
6
7
10
11
12
13

members.
14
15
16
17
18

19
20
21
22
23

24
25
26
27
aforesaid, did unlawfully attempt to murder OFFICER J. GRIFFIN
28
55.
3
4
5
6
7
8

9
10
11
12
13

14
15
16

17
18
19
20
21
22
23
24
25
26
27
28
56.
members.
3
4
5
6

7
8
9
10
11
12
13
14
15
16
aforesaid, did unlawfully attempt to murder SERGEANT P. SMITH

17
18
19
20
21
22
23
24
25
26
27
28

57.
4
5
6
7
10
11
12
13

14
15
16
17
18

members.
19
20
21
22
23
24
25
26
27
28
58.
1
2
3

4
5
6
7

aforesaid, did unlawfully attempt to murder SERGEANT I. ROSE #1217,
10
the defendant.
11
12
13

14
15
16

17
18
19
20
21
22
23

24
25
26
27
28
59.
1
2
3

4
5
6
7
10
11
12
13

members.
14
15
16
17
18

19
20
21
22
23

24
25
26
27
aforesaid, did unlawfully attempt to murder OFFICER N. URIAS #2316
, who was a peace officer/firefighter engaged in the performance of
28
60.
the defendant.
3
4
5
6
7
8

9
10
11
12
13

14
15
16

17
18
19
20
21
22
23
24
25
26
27
28
61.
members.
3
4
5
6

7
8
9
10
11
12
13
14
15
16
aforesaid, did unlawfully attempt to murder OFFICER M. SANDBERG

17
18
19
20
21
22
23
24
25
26
27
28

62.
4
5
6
7
10
11
12
13

14
15
16
17
18

members.
19
20
21
22
23
24
25
26
27
28
63.
1
2
3

4
5
6
7

aforesaid, did unlawfully attempt to murder OFFICER M. RODRIGUEZ
10
11
12
13

14
15
16

17
18
19
20
21
22
23

24
25
26
27
28
64.
1
2
3

4
5
6
7
10
11
12
13

members.
14
15
16
17
18

19
20
21
22
23

California, JAIME RAMOS and PABLO RUVALCABA, did commit the crime
24
25
26
27
aforesaid, did unlawfully attempt to murder OFFICER RONALD MAXWELL
28
65.
3
4
5
6
7
8

9
10
11
12
13

14
15
16

17
18
19
20
21
22
23
24
25
26
27
28
66.
members.
3
4
5
6

7
8
9
10

11
12
13
14

aforesaid, did unlawfully attempt to murder OFFICER LARRY WRIGHT,
15
16
17
the defendant.
18
19
20

21
22
23

24
25
26
27
28

67.
3
4
5
6
7
8

9
10
11
12
13

14
15
16
17

members.
18
19
20
21
22
23
24
25
26
27
28
68.
1
2
3

4
5
6
7

aforesaid, did unlawfully attempt to murder OFFICER TOM HESLIN
10
11
12
13

14
15
16

17
18
19
20
21
22
23

24
25
26
27
28
69.
1
2
3

4
5
6
7
10
11
12
13

members.
14
15
16
17
18

19
20
21
22
23

24
25
26
27
aforesaid, did unlawfully attempt to murder OFFICER ELLIOT BECKER
28
70.
3
4
5
6
7
8

9
10
11
12
13

14
15
16

17
18
19
20
21
22
23
24
25
26
27
28
71.
members.
3
4
5
6

7
8
9
10
11
12
13
14
15
16
aforesaid, did unlawfully attempt to murder OFFICER CHRISTOPHER

SLATE #1723, who was a peace officer/firefighter engaged in the
17
18
19
20
21
22
23
24
25
26
27
28

72.
4
5
6
7
10
11
12
13

14
15
16
17
18

members.
19
20
21
22
23
24
25
26
27
28
73.
1
2
3

4
5
6
7

aforesaid, did unlawfully attempt to murder OFFICER GEORGE CAMACHO
#2594 , who was a peace officer/firefighter engaged in the
10
11
12
13

14
15
16

17
18
19
20
21
22
23

24
25
26
27
28
74.
1
2
3

4
5
6
7
10
11
12
13

members.
14
15
16
17
18

19
20
21
22
23

24
25
26
27
aforesaid, did unlawfully attempt to murder OFFICER JULIO MORALES
28
75.
3
4
5
6
7
8

9
10
11
12
13

14
15
16

17
18
19
20
21
22
23
24
25
26
27
28
76.
members.
3
4
5
6

7
8
9
10
11
12
13
14
15
16
aforesaid, did unlawfully attempt to murder OFFICER BRAD BURRELL

#2096 , who was a peace officer/firefighter engaged in the
17
18
19
20
21
22
23
24
25
26
27
28

77.
4
5
6
7
10
11
12
13

14
15
16
17
18

members.
19
20
21
22
23
24
25
26
27
28
78.
1
2
3

4
5
6
7

aforesaid, did unlawfully attempt to murder OFFICER LANCE BAUER,
10
the defendant.
11
12
13

14
15
16

17
18
19
20
21
22
23

24
25
26
27
28
79.
1
2
3

4
5
6
7
10
11
12
13

members.
14
15
16
17
18

19
20
21
22
23

24
25
26
27
aforesaid, did unlawfully attempt to murder OFFICER KEVIN KNALL
28
80.
3
4
5
6
7
8

9
10
11
12
13

14
15
16

17
18
19
20
21
22
23
24
25
26
27
28
81.
members.
3
4
5
6

7
8
9
10
11
12
13
14
15
16
aforesaid, did unlawfully attempt to murder OFFICER RODGER HOLSCHER

17
18
19
20
21
22
23
24
25
26
27
28

82.
4
5
6
7
10
11
12
13

14
15
16
17
18

members.
19
20
21
22
23
24
25
26
27
28
83.
1
2
3

4
5
6
7

aforesaid, did unlawfully attempt to murder OFFICER DAVE HILAND
10
11
12
13

14
15
16

17
18
19
20
21
22
23

24
25
26
27
28
84.
1
2
3

4
5
6
7
10
11
12
13

members.
14
15
16
17
18

19
20
21
22
23

24
25
26
27
aforesaid, did unlawfully attempt to murder OFFICER GUSTAVO
ARRELLANO #17405, who was a peace officer/firefighter engaged in
28
85.
the performance of duty and this was known, and reasonably should
have been known by the defendant.
3
4
5
6
7
8

9
10
11
12
13

14
15
16

17
18
19
20
21
22
23
24
25
26
27
28
86.
members.
3
4
5
6

7
8
9
10
11
12
13
14
15
16
aforesaid, did unlawfully attempt to murder OFFICER DANIEL VELARDE

17
18
19
20
21
22
23
24
25
26
27
28

87.
4
5
6
7
10
11
12
13

14
15
16
17
18

members.
19
20
21
22
23
24
25
26
27
28
88.
1
2
3
COUNT 46: POSSESSION OF ASSAULT WEAPON PC.30605(a)

California, JAIME RAMOS, did commit the crime of POSSESSION OF
4
5
6
7
ASSAULT WEAPON, in violation of Section 30605(a) of the Penal Code,

a FELONY, who at the time and place last aforesaid, did willfully
and unlawfully possess an assault weapon.
8
9
10
11
12
13

14
15
16
17
18
19
20
21
22
23
COUNT 47: CRIMINAL STREET GANG ACTIVITY PC.186.22(A)

California, JAIME RAMOS AND PABLO RUVALCABA , did commit the crime
24
25
26
27
28
of CRIMINAL STREET GANG ACTIVITY, in violation of Section 186.22(a)

of the Penal Code, a FELONY, who at the time and place last
aforesaid did willfully and unlawfully actively participate in a
criminal street gang with the knowledge that the gang members did
89.
engage in a pattern of criminal gang activity, and did willfully
promote, further or assist in felonious criminal conduct by members
of that gang.
4
5
6
7
10
11
12
1192.7(c)(8).
13
14
15
A TRUE BILL
JAMES P. WILLETT
16
DISTRICT ATTORNEY
County of San Joaquin
State of California
17
18
19
FOREMAN OF THE GRAND JURY
Deputy District Attorney
20
DATE:
DATE: _____________________
______________________
21
22
23
24
25
26
27
28
90.

Jaime Ramos Pablo Ruvalcaba Indictment

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Jaime Ramos Pablo Ruvalcaba Indictment

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1

IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA

The Grand Jury of the County of San Joaquin, State of California,

COUNT 1: WILLFUL, DELIBERATE, PREMEDITATED MURDER PC.187(A)<F22

On or about July 16, 2014, in the County of San Joaquin,

of WILLFUL, DELIBERATE, PREMEDITATED MURDER, in violation of

alleged that the aforesaid murder was committed willfully,

SPECIAL CIRCUMSTANCE: MULTIPLE MURDERS PC.190.2(A)(3)

SPECIAL CIRCUMSTANCE: ROBBERY PC.190.2(A)(17)(A)

It is further alleged that the murder of MISTY HOLT-SINGH was

COMMITTED by defendant, JAIME RAMOS , while the said defendant

ENGAGED IN THE COMMISSION OF the crime of ROBBERY, within the

SPECIAL CIRCUMSTANCE: KIDNAPPING PC.190.2(A)(17)(B)

It is further alleged that the murder of MISTY HOLT-SINGH was

committed by defendant, JAIME RAMOS , while the said defendant was

engaged in the commission of the crime of Kidnapping in violation

of Penal Code Section 207 and 209.

SPECIAL CIRCUMSTANCE: BURGLARY MURDER PC.190.2(A)(17)(G)

It is further alleged that the murder of MISTY HOLT-SINGH was

the crime of BURGLARY, within the

meaning of Penal Code Section 190.2(a)(17)(g).

SPECIAL CIRCUMSTANCE: MURDER COMMITTED CRIMINAL STREET GANG

It is further alleged, pursuant to Penal Code Section 190.2(a)(22),

that the defendant, JAIME RAMOS , intentionally killed MISTY HOLT-

SINGH while the defendant was an active participant in a criminal

activities of the criminal street gang.

PRINCIPAL'S INTENTIONAL DISCHARGE OF A FIREARM, GBI-GANG CASE

and proximately caused great bodily injury as defined in Penal Code

CRIMINAL STREET GANG ACTIVITY PC.186.22(B)(1)

criminal street gang, and with the specific intent to promote,

SPECIAL CIRCUMSTANCE: MULTIPLE MURDERS PC.190.2(A)(3)

SPECIAL CIRCUMSTANCE: ROBBERY PC.190.2(A)(17)(A)

It is further alleged that the murder of MISTY HOLT-SINGH was

COMMITTED by defendant, PABLO RUVALCABA , while the said defendant

AN ACCOMPLICE IN THE COMMISSION OF

the crime of ROBBERY,

within the meaning of Penal Code Section 190.2(a)(17)(a).

SPECIAL CIRCUMSTANCE: KIDNAPPING PC.190.2(A)(17)(B)

It is further alleged that the murder of MISTY HOLT-SINGH was

committed by defendant, PABLO RUVALCABA , while the said defendant

was engaged in the commission of the crime of Kidnapping in

violation of Penal Code Section 207 and 209.

SPECIAL CIRCUMSTANCE: BURGLARY MURDER PC.190.2(A)(17)(G)

It is further alleged that the murder of MISTY HOLT-SINGH was

BURGLARY, within the meaning of Penal Code Section 190.2(a)(17)(g).

SPECIAL CIRCUMSTANCE: MURDER COMMITTED CRIMINAL STREET GANG

It is further alleged, pursuant to Penal Code Section 190.2(a)(22),

that the defendant, PABLO RUVALCABA , intentionally killed MISTY

HOLT-SINGH while the defendant was an active participant in a

further the activities of the criminal street gang.

PRINCIPAL'S INTENTIONAL DISCHARGE OF A FIREARM, GBI-GANG CASE

and proximately caused great bodily injury as defined in Penal Code

CRIMINAL STREET GANG ACTIVITY PC.186.22(B)(1)

association with a criminal street gang, and with the specific

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 2: WILLFUL, DELIBERATE, PREMEDITATED MURDER PC.187(A)<F22

On or about July 16, 2014, in the County of San Joaquin,

of WILLFUL, DELIBERATE, PREMEDITATED MURDER, in violation of

place last aforesaid did willfully, unlawfully, and with malice

aforethought murder ALEX MARTINEZ a human being. It is further

alleged that the aforesaid murder was committed willfully,