Allenbaugh Complaint

1 TORI VERBER SALAZAR
District Attorney
2 San Joaquin County
State Bar No. 213636
3
By: Edward McGarvey
4 Deputy District Attorney
222 E. Weber Avenue
5 Stockton, CA 95202
6 209.468.2400; Fax 209.465.0371

Attorneys for Plaintiff
7
8 SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN JOAQUIN
9 Lodi Branch
10 The People of the State of California, No. LP21-07406

LPD CASE
11
Plaintiff, DA Case: CR-2021-4259777
12
v. COMPLAINT
13 SPE
14 RANDALL LEE ALLENBAUGH
15
16
17
18 Defendant(s).
19
20 I, the undersigned, say, on information and belief, that in the
21 County of SAN JOAQUIN, State of California:

22
23
COUNT 1: MURDER PC.187(A)
24
On or about November 16, 2021, in the County of San Joaquin,
25
California, RANDALL LEE ALLENBAUGH, did commit the crime of MURDER,
26
27 in violation of Section 187(a) of the Penal Code, a FELONY, who at
28 the time and place last aforesaid, did willfully and unlawfully and
1
1 intentionally and with malice aforethought murder JANE C. DOE, DOB:
2 9/15/2005 a human being. It is further alleged that the above

3
offense is a serious felony within the meaning of Penal Code Section
4
1192.7(c)(1).
5
6
SPECIAL CIRCUMSTANCE: CONVICTED OF MULTIPLE MURDERS PC.190.2(a)(3)
7
It is further alleged that defendant, RANDALL LEE ALLENBAUGH, in
8
9 this proceeding, has been convicted of more than one offense of
10 murder in the first or second degree.
11
12 PERSONAL USE OF NON-FIREARM WEAPON PC.12022(B)(1)
13 It is further alleged that in the commission or attempted commission

14 of the above offense, the defendant, RANDALL LEE ALLENBAUGH, did
15
personally use a weapon, to-wit: KNIFE, within the meaning of Penal
16
Code Section 12022(b)(1). NOTICE: It is further alleged that the
17
above offense is a serious felony within the meaning of Penal Code
18
19 Sections 1192.7(c) and 1192.8.
20
21 For a further and separate cause of complaint, being a different
22 offense from but connected in its commission with the charge(s)
23
above, complainant further complains and says:
24
25
COUNT 2: MURDER PC.187(A)
26
On or about November 16, 2021, in the County of San Joaquin,
27
California, RANDALL LEE ALLENBAUGH, did commit the crime of MURDER,
28
2
1 in violation of Section 187(a) of the Penal Code, a FELONY, who at
2 the time and place last aforesaid, did willfully and unlawfully and
3
intentionally and with malice aforethought murder JOHN S. DOE, DOB:
4
9/9/2004 a human being. It is further alleged that the above offense
5
is a serious felony within the meaning of Penal Code Section
6
1192.7(c)(1).
7
8
SPECIAL CIRCUMSTANCE: CONVICTED OF MULTIPLE MURDERS PC.190.2(a)(3)
9
10 It is further alleged that defendant, RANDALL LEE ALLENBAUGH, in
11 this proceeding, has been convicted of more than one offense of

12 murder in the first or second degree.
13
14 PERSONAL USE OF NON-FIREARM WEAPON PC.12022(B)(1)
15
It is further alleged that in the commission or attempted commission
16
of the above offense, the defendant, RANDALL LEE ALLENBAUGH, did
17
personally use a weapon, to-wit: KNIFE, within the meaning of Penal
18
19 Code Section 12022(b)(1). NOTICE: It is further alleged that the
20 above offense is a serious felony within the meaning of Penal Code
21 Sections 1192.7(c) and 1192.8.

22
23
If the above-named defendant(s) is/are presently on probation in San
24
Joaquin County, any evidence presented at a preliminary hearing in
25
the instant case will be used not only as a basis for a holding
26
order in this case but also as evidence of a violation of probation
27
28 and, at any formal hearing on that violation of probation, the
3
1 People will move the transcript of the preliminary hearing into
2 evidence as a basis for the violation.

3
4
Pursuant to Penal Code Section 1054.5(b), the People hereby
5
informally request that the defendant and his/her attorney disclose
6
to the People all information and materials described in Penal Code
7
8 Section 1054.3.
9
10 I declare under penalty of perjury that the foregoing is true and
11 correct except for those things stated on information and belief and
12
those I believe to be true.
13
14
Executed on 11/17/2021, at Stockton, California.
15
16
17 ________________________________
18
19
20
rds
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1 TORI VERBER SALAZAR

6 209.468.2400; Fax 209.465.0371

10 The People of the State of California, No. LP21-07406

21 County of SAN JOAQUIN, State of California:

2 9/15/2005 a human being. It is further alleged that the above

10 murder in the first or second degree.

13 It is further alleged that in the commission or attempted commission

11 this proceeding, has been convicted of more than one offense of

20 above offense is a serious felony within the meaning of Penal Code

21 Sections 1192.7(c) and 1192.8.

2 evidence as a basis for the violation.

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