SUPERIOR COURT OF CALIFORNIA

COUNTY OF CONTRA COSTA

THE PEOPLE OF THE STATE OF CALIFORNIA,

Plaintiff,
v.
CHASE BRYAN LITTLE,
dob 09/20/1985;
COLTON TYE LEBLANC,
dob 04/09/1992;
Defendants.

Docket: 02-323861-5
DA No: 0130920655
COMPLAINT - FELONY
Count 1) PC245(a)(4)
Count 2) PC245(a)(1)

COUNT 1 ASSAULT BY MEANS LIKELY TO PRODUCE GREAT BODILY INJURY

The undersigned states, on information and belief, that Chase Bryan Little, and Colton Tye Leblanc,
Defendants, did commit a Felony, a violation of PC245(a)(4), Assault By Means Likely To Produce Great
Bodily Injury, committed as follows:
On or about September 25, 2016, in the City of RIchmond, County of Contra Costa, State of California, the
crime of Assault By Means Likely To Produce Great Bodily Injury in violation of PC245(a)(4), a Felony, was
committed in that CHASE BRYAN LITTLE AND COLTON TYE LEBLANC did willfully and unlawfully commit
an assault on Maan Singh Khalsa by means of force likely to produce great bodily injury.
ENHANCEMENT 1
PC422.75(b): Special Allegation-Hate Crime, In Concert
It is further alleged as to Count 1 that the above offense is a Hate Crime and that defendants, CHASE
BRYAN LITTLE AND COLTON TYE LEBLANC committed the offense voluntarily and in concert with
another and others in violation of Penal Code Section 422.75(b).
ENHANCEMENT 2
PC12022.7(a): Special Allegation-Great Bodily Injury
It is further alleged as to Count 1 that in the commission of the above offense the said defendants, CHASE
BRYAN LITTLE AND COLTON TYE LEBLANC, personally inflicted great bodily injury upon Maan Singh
Khalsa, not an accomplice to the above offense, within the meaning of Penal Code Section 12022.7(a) and
also causing the above offense to become a serious felony within the meaning of Penal Code Section
1192.7(c)(8).

COUNT 2 ASSAULT WITH A DEADLY WEAPON

The undersigned states, on information and belief, that Chase Bryan Little, and Colton Tye Leblanc,
Defendants, did commit a Felony, a violation of PC245(a)(1), Assault With A Deadly Weapon, committed as
follows:

PEOPLE vs. CHASE BRYAN LITTLE, COLTON TYE LEBLANC

Docket: 02-323861-5
Page 2 of 2

On or about September 25, 2016, in the City of Richmond County of Contra Costa, State of California, the
crime of Assault With A Deadly Weapon in violation of PC245(a)(1), a Felony, was committed in that
CHASE BRYAN LITTLE AND COLTON TYE LEBLANC did willfully and unlawfully commit an assault upon
Maan Singh Khalsa with a deadly weapon, to wit, Knife.

ENHANCEMENT 1
PC422.75(b): Special Allegation-Hate Crime, In Concert
It is further alleged as to Count 2 that the above offense is a hate crime and that defendants, CHASE
BRYAN LITTLE AND COLTON TYE LEBLANC committed the offense voluntarily and in concert with
another and others in violation of Penal Code Section 422.75(b).
ENHANCEMENT 2
PC12022.7(a): Special Allegation-Great Bodily Injury
It is further alleged as to Count 2 that in the commission of the above offense the said defendants, CHASE
BRYAN LITTLE AND COLTON TYE LEBLANC, personally inflicted great bodily injury upon Maan Singh
Khalsa, not an accomplice to the above offense, within the meaning of Penal Code Section 12022.7(a) and
also causing the above offense to become a serious felony within the meaning of Penal Code Section
1192.7(c)(8).

Complainant requests that the Defendant[s] be dealt with according to the law.
Dated: October 14, 2016, at Richmond, California
MARK A. PETERSON
District Attorney

Simon O'Connell
Deputy District Attorney
SO/ga