Amended Information Filing Document

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SUPERIOR COURT OF CALIFORNIA COUNTY OF SAN BERNARDINO
THE PEOPLE OF THE STATE OF CALIFORNIA,
Plaintiff
vs.
Louie Montenegro ,
Robert Montenegro ,
Alisha Mendoza
aka Alicia Mendoza
)
)
)
)
)
)
)
)
)
)
)
)
)
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COURT CASE NO. FWV1201178
FIRST AMENDED
INFORMATION
Arraignment Date: 11/09/12
Department: R2
DA CASE NO. 2012-00-0025100
Defendant
I N F O R M A T I O N
S U M M A R Y _ _
Ct.
No.
1
Charge
PC206
2
PC206
Charge
Range
Life
Life
3
PC273d(a)
4
PC273d(a)
5
PC273a(a)
6
PC273a(a)
Special
Allegation
Alleg.
Effect
Louie Montenegro
Robert Montenegro
PC12022.7(d)
PC12022.7(d)
5-6
5-6
Louie Montenegro
Robert Montenegro
PC12022.7(d)
5-6
Defendant
Louie Montenegro
Robert Montenegro
Louie Montenegro
Robert Montenegro
2-4-6
2-4-6
Alisha Mendoza
Alisha Mendoza
2-4-6
2-4-6
Page 1
Amended Information
DA CASE NO: 2012-00-0025100
The District Attorney of the County of San Bernardino, by this Information alleges that:
COUNT 1
On or about May 13, 2012, in the above named judicial district, the crime of TORTURE,
in violation of PENAL CODE SECTION 206, a felony, was committed by Louie Montenegro and
Robert Montenegro, 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 12022.7, upon Jane Doe.
"NOTICE: Conviction of this offense will require you to provide specimens and samples
pursuant to Penal Code section 296. Willful refusal to provide the specimens and samples is a
crime."
*****
COUNT 2
On or about May 13, 2012, in the above named judicial district, the crime of TORTURE,
in violation of PENAL CODE SECTION 206, a felony, was committed by Louie Montenegro and
Robert Montenegro, 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 12022.7, upon John Doe.
"NOTICE: Conviction of this offense will require you to provide specimens and samples
pursuant to Penal Code section 296. Willful refusal to provide the specimens and samples is a
crime."
*****
COUNT 3
On or about May 13, 2012, in the above named judicial district, the crime of
CORPORAL INJURY TO CHILD, in violation of PENAL CODE SECTION 273d(a), a felony, was
committed by Louie Montenegro and Robert Montenegro, who did willfully and unlawfully inflict cruel
Page 2
Amended Information
DA CASE NO: 2012-00-0025100
and inhuman corporal punishment and injury, resulting in a traumatic condition, upon a child, to wit,
Jane Doe.
"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse
Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5 limit
access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the report."
It is further alleged, within the meaning of Penal Code section 12022.7(d), as to count(s)
3 that defendants Louie Montenegro and Robert Montenegro personally inflicted great bodily injury
on Jane Doe who was under the age of five years.
*****
COUNT 4
On or about May 13, 2012, in the above named judicial district, the crime of
CORPORAL INJURY TO CHILD, in violation of PENAL CODE SECTION 273d(a), a felony, was
committed by Louie Montenegro and Robert Montenegro, who did willfully and unlawfully inflict cruel
and inhuman corporal punishment and injury, resulting in a traumatic condition, upon a child, to wit,
John Doe.
"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse
Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5 limit
access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the report."
It is further alleged, within the meaning of Penal Code section 12022.7(d), as to count(s)
4 that defendant Louie Montenegro personally inflicted great bodily injury on John Doe who was
under the age of five years.
*****
COUNT 5
On or about May 13, 2012, in the above named judicial district, the crime of CHILD
ABUSE, in violation of PENAL CODE SECTION 273a(a), a felony, was committed by Alisha
Page 3
Amended Information
DA CASE NO: 2012-00-0025100
Mendoza, who did willfully and unlawfully, under circumstances likely to produce great bodily harm
and death, injure, cause, and permit a child, Jane Doe, to suffer and to be inflicted with unjustifiable
physical pain and mental suffering, and, having the care and custody of said child, injure, cause, and
permit the person and health of said child to be injured and did willfully cause and permit said child to
be placed in such situation that his/her person and health was/were endangered.
"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse
Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5 limit
access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the report."
*****
COUNT 6
On or about May 13, 2012, in the above named judicial district, the crime of CHILD
ABUSE, in violation of PENAL CODE SECTION 273a(a), a felony, was committed by Alisha
Mendoza, who did willfully and unlawfully, under circumstances likely to produce great bodily harm
and death, injure, cause, and permit a child, John Doe, to suffer and to be inflicted with unjustifiable
physical pain and mental suffering, and, having the care and custody of said child, injure, cause, and
permit the person and health of said child to be injured and did willfully cause and permit said child to
be placed in such situation that his/her person and health was/were endangered.
"NOTICE: Pursuant to Penal Code Section 11166 and 11168, a Suspected Child Abuse
Report (SCAR) may have been generated in this case. Penal Code Section 11167 and 11167.5 limit
access to a SCAR. A protective order issued by a court is necessary to obtain a copy of the report."
*****
*
*
*
*
*
Pursuant to Penal Code Section 1054.5(b), the People are hereby informally requesting that defense
counsel provide discovery to the People as required by Penal Code Section 1054.3.
THIS INFORMATION CONSISTS OF 6 COUNT(S).
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Amended Information
DA CASE NO: 2012-00-0025100
MICHAEL A. RAMOS
DISTRICT ATTORNEY
County of San Bernardino
State of California
By:
Karen Schmauss
Karen Schmauss
Deputy District Attorney
Filed in Superior Court,
County of San Bernardino
Dated: _______________
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Amended Information
DA CASE NO: 2012-00-0025100
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