1 2 ANNE MARIE SCHUBERT SSD-78-7457 3 DISTRICT ATTORNEY R. NORGAARD, DDA 4 901 G STREET TEAM: MC 5 SACRAMENTO, CA 95814 XRef: 46180 6 (916) 874-6218 7 8 SUPERIOR COURT OF 9 COUNTY OF SACRAMENTO 10 11 THE PEOPLE OF THE STATE OF CALIFORNIA, FELONY COMPLAINT 12 vs. 13 JOSEPH JAMES DEANGELO , 14 Defendant. 15 16 17 The People of the State of California upon oath of the undersigned, upon information and belief 18 19 complain against the defendant above named for the crime( s) as follows: 20 21 COUNT ONE 22 On or about February 2, 1978, at and in the County of Sacramento, State of California, the 23 defendant, JOSEPH JAMES DEANGELO, did commit a felony, namely: a violation of Section 24 187(a) of the Penal Code of the State of California, in that said defendant did unlawfully, and 25 with malice aforethought KATIE MAGGIORE, a human being. 26 27 28 "NOTICE: The above offense is a serious and violent felony within the meaning of Penal Code 29 Sections 1192.7(c)(l) and 667.5(c)(l)." 30 31 It is further alleged that in the commission and attempted commission of the above offense(s), 32 the said defendant, JOSEPH JAMES DEANGELO, personally used a firearm, to wit, an 33 34 unknown caliber firearm, within the meaning of Penal Code Sections 1203.06(a)(l) and 35 12022.5(a) also causing the above offense to become a serious felony pursuant to Penal Code 36 Section 1192.7(c)(8) and a violent felony within the meaning of Penal Code Section 667.5(c)(8). 37 38 39 40 1 Illllll 111111111111111111111111111111111 41 880662 1 2 3 COUNT TWO 4 For a further and separate cause of action, being a different offense of the same class of crimes 5 and offenses and connected in its commission with the charges set forth in Count One hereof: On 6 or about February 2, 1978, at and in the County of Sacramento, State of California, the 7 8 defendant, JOSEPH JAMES DEANGELO, did commit a felony, namely: a violation of Section 9 187(a) of the Penal Code of the State of California, in that said defendant did unlawfully, and 10 with malice aforethought murder BRIAN MAGGIORE, a human being. 11 12 "NOTICE: The above offense is a serious and violent felony within the meaning of Penal Code 13 Sections 1192.7(c)(l) and 667.S(c)(l)." 14 15 16 It is further alleged that in the commission and attempted commission of the above offense( s ), 17 the said defendant, JOSEPH JAMES DEANGELO, personally used a firearm, to wit, an 18 unknown caliber firearm, within the meaning of Penal Code Sections 1203.06(a)(l) and 19 12022.S(a) also causing the above offense to become a serious felony pursuant to Penal Code 20 Section 1192.7(c)(8) and a violent felony within the meaning of Penal Code Section 667.5(c)(8). 21 22 23 SPECIAL CIRCUMSTANCE 24 1. 25 It is further alleged that the offenses charged in Counts One and Two are a special circumstance, 26 in that the defendant committed multiple , within the meaning of Penal Code Section 27 190.2(c)(5). 28 29 That attached hereto and by this reference incorporated herein is a declaration setting forth facts 30 31 in support of probable cause for the issuance of a warrant of arrest herein. 32 33 I declare upon information and belief and under penalty of perjury that the foregoing is true and 34 correct. 35 36 37 38 39 40 2 Illllll 111111111111111111111111111111111 41 880662 1 2 3 Executed at Sacramento County, California, the 24th day of April, 2018. 4 5 --z_;ยต 6 7 8 9 ROD NORGAARD 10 SACRAMENTO COUNTY DISTRICT ATTORNEY 11 (916) 874.-6218 12 Telephone Number 13 NR 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 3 Illllll 111111111111111111111111111111111 41 880662 1 2 3 HOLDING ORDER 4 5 __ It appearing to me that the offense(s) in the within complaint has/have been committed, 6 and that there is sufficient cause to believe that the defendant, JOSEPH JAMES 7 8 DEANGELO, is guilty thereof, 9 __ The defendant, JOSEPH JAMES DEANGELO, having waived preliminary hearing to the 10 offense( s) set forth in this complaint, 11 12 13 14 15 16 17 I order that the defendant be held to answer to same. In my capacity as Judge of the Superior 18 Court, I deem the within complaint to be an Information and order it filed in the Superior Court. 19 20 Date: _____ Dept: ___ 21 22 Judge of the Superior Court Sitting as Magistrate 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 4 Illllll 111111111111111111111111111111111 41 880662 1 2 3 DECLARATION IN SUPPORT OF ARREST WARRANT 4 (Made under 2015.5 CCP) 5 6 7 The undersigned hereby declares: 8 That your declarant is currently employed as a Deputy District Attorney for the County of 9 Sacramento, State of California. 10 That pursuant to said employment, your declarant has been assigned to investigate 11 allegations that the defendant, JOSEPH JAMES DEANGELO, did commit the crime(s) as set 12 forth in the attached complaint. 13 That pursuant to said assignment, your declarant has contacted person( s) having 14 15 knowledge of said offense( s) and who has/have prepared written reports and/or statements, 16 and/or has received and read written reports and/or statements prepared by others known by your 17 declarant to be law enforcement officers, all of which reports and/or statements are included in a 18 report consisting of 48 page( s ), which is attached hereto as Exhibit I and incorporated by 19 references as though fully set forth. 20 That each of these documents is presently an official record of a law enforcement agency. 21 22 WHEREFORE, your declarant prays that a warrant issue for the arrest of the 23 hereinabove-named defendant and that said defendant be dealt with according to law. 24 I declare under penalty of perjury that the foregoing is true and correct. 25 Executed on the 24th day of April, 2018, Sacramento, California. 26 27 28 29 30 31 32 33 ROD NORGAARD 34 Declarant 35 901 G Street, 36 Sacramento, California 95814 37 Sacramento County District Attorney 38 39 40 5 Illllll lllll lllll lllll lllll lllll llll llll 41 880662