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SUPERIOR COURT OF .. , . , U: ''''"}IW'
COUNTY OF SAN BERNARDINO ' N BlchOIARDiNO DISTR/Cl.. C
CENTRAL DISTRICT OCT 1 7 20i
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BY C72
COURT CASE NO----L 71'-i.
FSB 1 3 0 4 4 r 8
THE PEOPLE OF THE STATE OF CALIFORNIA,
Plaintiff,
vs.
FELONY COMPLAINT
Chas Allen Kelley,
Defendant.
The undersigned is informed and believes that:
COUNT 1
On or about January 31, 2007, through, and including, July 30, 2012, in the above named judicial
district, the crime of PERJURY BY CERTIFICATION, in violation of PENAL CODE SECTION 118,
a felony, was committed by Chas Allen Kelley, who did unlawfully and willfully, under penalty of
perjury, certify as true, in a case in which such certification is permitted by law, material matter
which he knew was false, intending that it be circulated or published as true, to wit: contributions
received and expenditures made by the Friends of Chas Kelley committee during the July 1, 2006,
to June 30, 2012, reporting periods on Fair Political Practices Commission Forms 460.
*****
SPECIAL ALLEGATION: Penal Code Section 803( c) and
People v. Zamora (1976) 18 Cal. 3d 538
As to Count 1, it is further alleged that the following facts are true:
1. The offense(s) were discovered sometime on or after October 12, 2011.
2. The offense(s) were discovered by San Bernardino County District Attorney Senior
Investigator Schyler Beaty ("SI Beaty.")
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Felony Complaint
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On October 12, 2011, Sl Beaty received a general complaint about Chas Allen Kelley, a
Council Member for the City of San Bernardino, for the first time.
As part of investigating the complaint about Chas Allen Kelley, Sl Beaty obtained copies of
Chas Allen Kelley's personal and campaign banking records and campaign disclosure records.
The first of these records were obtained on February 29, 2012. Additional records were obtained
in the latter part of 2012 and throughout 2013 to date. A review of these records revealed the
crimes that are alleged in Count 1.
3. Law enforcement officials had no actual or constructive knowledge of the offenses prior to
October 12, 2011.
4. The offenses could not have been discovered earlier with reasonable diligence because
there was absolutely no report of, or any reason to suspect, any kind of illegal activity on the part of
Chas Allen Kelley either in general, or specifically with respect to disclosures of Chas Allen Kelley's
campaign contributions or expenditures, at any time prior to October 12, 2011, and obtaining of
Chas Allen Kelley's personal and campaign banking records and campaign disclosure records.
* * * * *
NOTICE TO DEFENDANT AND DEFENDANT'S ATTORNEY
Pursuant to Penal Code Sections 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.
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 1054.2 which provides: "No
attorney may disclose or permit to be disclosed to a defendant the address or telephone number of
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Felony Complaint
a victim or witness whose name is disclosed to the attorney pursuant to subdivision (a) of Section
1054.1 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 1 COUNT.
Executed at San Bernardino, California, on October 16, 2013.
Agency: District Attorney B of I - Public Integrity Unit
Defendant
Chas Allen Kelley
Felony Complaint
Birth Date
12/15/1968
Booking No.
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b COMPLAINANT
Prelim Est. 00:00
Cll No. NCIC