10 " 2 13 1“ 18 16 7 18 19 20 2 2 23 24 25 26 ar 28 CLIFFORD H. NEWELL (SBN 204426) Nevada County District Attorney 201 Commercial Street Nevada City, CA 95959 Tel: (530) 265-1301 IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA IN AND FOR THE COUNTY OF NEVADA THE PEOPLE OF THE STATE OF CALIFORNIA, Case No.: Plaintiff, FELONY COMPLAINT -vs- DAKARI MONDELL HARRIS (A) DOB: 09/04/1998 DEVON DEONTAE JENNINGS (B) DOB: 12/01/1998 WILLIAM RYNELL LEVISE (C) DOB: 10/11/1989 TREY RONDAL RICHARD (D) DOB: 05/10/1998 RONNEY TURNER (E) DOB: 10/01/1989 LADERRICK TIMOTHY WYNN (F) DOB: 10/10/2000 Defendants. The District Attorney of the County of Nevada hereby accuses the defendants of: FELONY COMPLAINT t10 1" 2 13 14 6 16 7 18 19 20 2 22 23 24 25 26 27 28 COUNT I On or about November 7, 2020, in the County of Nevada, State of California, the crime of Conspiracy To Commit A Crime in violation of PC182(a)(1), a Felony, was committed in that DAKARI MONDELL HARRIS AND DEVON DEONTAE JENNINGS AND WILLIAM RYNELL LEVISE AND TREY RONDAL RICHARD AND RONNEY TURNER AND LADERRICK TIMOTHY WYNN did unlawfully conspire together and with another person and persons whose identity is unknown to commit the crime of Transportation of Marijuana, in violation of Section 11360(a)(3)(D) of the Health and Safety Code, a felony; that pursuant to and for the purpose of carrying out the objectives and purposes of the aforesaid conspiracy, the said defendants, DAKAR! MONDELL HARRIS AND DEVON DEONTAE JENNINGS AND WILLIAM RYNELL LEVISE AND TREY RONDAL RICHARD AND RONNEY TURNER AND LADERRICK TIMOTHY WYNN, and unknown co-conspirators, committed the following overt act and acts: 1. Travelled from Texas to California 2. Rented Vehicles 3. Booked hotels 4, Bundled together fake money 5, Setup a marijuana purchase 6. Fled from the scene COUNT I On or about November 7, 2020, in the County of Nevada, State of California, the crime of Conspiracy To Commit A Crime in violation of PC182(a)(1), a Felony, was committed in that DAKARI MONDELL HARRIS AND DEVON DEONTAE JENNINGS AND WILLIAM RYNELL. LEVISE AND TREY RONDAL RICHARD AND RONNEY TURNER AND LADERRICK TIMOTHY WYNN did unlawfully conspire together and with another person and persons whose identity is unknown to commit the crime of Grand Theft by False Pretenses, in violation FELONY COMPLAINT 210 " 2 13 14 18 16 v7 18 9 20 a 2 23 24 25 26 2 28 of Section 484 of the Penal Code, a felony; that pursuant to and for the purpose of carrying out| the objectives and purposes of the aforesaid conspiracy, the said defendants, DAKARI MONDELL HARRIS AND DEVON DEONTAE JENNINGS AND WILLIAM RYNELL LEVISE AND TREY RONDAL RICHARD AND RONNEY TURNER AND LADERRICK TIMOTHY WYNN, and unknown co-conspirators, committed the following overt act and acts: 1. Travelled from Texas to California 2. Rented Vehicles 3. Booked hotels 4, Bundled together fake money 5, Setup a marijuana purchase 6. Fled from the scene COUNT III ‘On or about November 7, 2020, in the County of Nevada, State of California, the crime of Shooting At Occupied Motor Vehicle in violation of PC246, a Felony, was committed in that DAKARI MONDELL HARRIS AND DEVON DEONTAE JENNINGS AND DEVON DEONTAE JENNINGS AND WILLIAM RYNELL LEVISE AND WILLIAM RYNELL LEVISE AND TREY RONDAL RICHARD AND TREY RONDAL RICHARD AND RONNEY TURNER AND RONNE’ TURNER AND LADERRICK TIMOTHY WYNN AND LADERRICK TIMOTHY WYNN did willfully, unlawfully, and maliciously discharge a firearm at an occupied motor vehicle. NOTICE: The above offense is a serious felony within the meaning of Penal Code Section 1192.7(¢) NOTICE: It is further alleged that pursuant to Penal Code section 1203.095, there is a presumptive minimal jail time required if you are convicted of this charge. NOTICE: The above offense is a serious felony within the meaning of Penal Code Section 1192.7(¢). FELONY COMPLAINT 310 " 2 13 14 15 16 7 19 20 a 22 23 24 25 26 27 28 Special Allegation-Personal And Intentional Disch: fA Firearm, Causing GBI or Death: PC 12022.53(d Itis further alleged as to Count Ill that defendant, TREY RICHARD personally and intentionally| discharged a firearm, a handgun, which caused great bodily injury and death to Shanta Olsen within the meaning of Penal Code Section 12022.53(d) also causing the above offense to become a serious felony pursuant to Penal Code section 1192.7(c)(8) and a violent felony within the meaning of Penal Code section 667.5(c)(8). | declare under penalty of perjury that the foregoing is true and correct. Executed on November 13, 2020, at Nevada City, Nevada County, California. CLIFFORD H. NEWELL, DISTRICT ATTORNEY #26 As nw By: CHRISTOPHER J. WALSH, ASSISTANT DISTRICT ATTORNEY DAM: 08720-003534 ‘Agency: GVPD Report #: G2003023 Booking#: 820002084 IC Bac: Grube cuWiejw FELONY COMPLAINT 428 ar 28 NOTICE: PURSUANT TO PENAL CODE SECTIONS 1054.5(b) AND 1054.3, THE DISTRICT ATTORNEY HEREBY MAKES AN INFORMAL DEMAND FOR DISCOVERY WITHIN FIFTEEN DAYS. Additionally, the People request that defense counsel provide any statements made by the defendant's intended witnesses, including the substance of oral statements that defense witnesses have made directly to defense counsel Roland v. Superior Court,124 Cal.App.4th 154, 21 Cal.Rptr.3d 151. FELONY COMPLAINT 3