SUPERIOR COURT OF CALIFORNIA, COUNTY OF SAN BERNARDINO

RANCHO CUCAMONGA DISTRICT

THE PEOPLE OF THE STATE OF CALIFORNIA,
Plaintiff
vs.
J effery J erome Bullard J r,
aka J effrey J erome Bullard,
Shazad Khan

Defendant
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COURT CASE NO




FELONY COMPLAINT


DA CASE NO 2014-00-0035724

The undersigned is informed and believes that:
COUNT 1
On or about J uly 8, 2014, in the above named judicial district, the crime of MURDER, in
violation of PENAL CODE SECTION 187(a), a felony, was committed by Shazad Khan, who did
unlawfully, and with malice aforethought murder Mitchell Papoose , a human being.

"NOTICE: The above offense is a serious felony within the meaning of Penal Code section
1192.7(c) and a violent felony within the meaning of Penal Code section 667.5(c)."

"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."
It is further alleged as to count(s) 1 that said defendant(s) Shazad Khan personally and
intentionally discharged a firearm, a handgun, which caused great bodily injury and death to
Mitchell Papoose 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).
It is further alleged as to count(s) 1 that said defendant(s) Shazad Khan personally and
intentionally discharged a firearm, a handgun, within the meaning of Penal Code Section
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Complaint DA CASE NO: 2014-00-0035724
12022.53(c) 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).
It is further alleged as to count(s) 1 that said defendant(s) Shazad Khan personally used a
firearm, a handgun, within the meaning of Penal Code Section 12022.53(b) 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).

It is further alleged that pursuant to Penal Code section 1170(h)(3) defendant(s) Shazad
Khan is eligible for imprisonment in the state prison due to:
the current charge is a serious or violent felony;
defendant(s) Shazad Khan has a prior serious or violent felony conviction;
defendant(s) Shazad Khan has been convicted of a crime with a Penal Code section 186.11
enhancement;
the crime is not punishable pursuant to Penal Code section 1170(h)(3).

*****
COUNT 2
On or about J uly 8, 2014, in the above named judicial district, the crime of ATTEMPTED
WILLFUL, DELIBERATE, AND PREMEDITATED MURDER, in violation of PENAL CODE
SECTION 664/187(a), a felony, was committed by Shazad Khan, who did unlawfully and with
malice aforethought attempt to murder J atwone Tyrell Phillips , a human being.
It is further alleged that the aforesaid attempted murder was committed willfully, deliberately
and with premeditation within the meaning of Penal Code section 664(a) and is a serious felony
pursuant to Penal Code section 1192.7(c).
It is further alleged as to count(s) 2, 3, 4, 5 that said defendant(s) Shazad Khan personally
and intentionally discharged a firearm, a handgun, within the meaning of Penal Code Section
12022.53(c) 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).
It is further alleged as to count(s) 2, 3, 4, 5 that said defendant(s) Shazad Khan personally
used a firearm, a handgun, within the meaning of Penal Code Section 12022.53(b) also causing
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Complaint DA CASE NO: 2014-00-0035724
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).

It is further alleged that pursuant to Penal Code section 1170(h)(3) defendant(s) Shazad
Khan is eligible for imprisonment in the state prison due to:
the current charge is a serious or violent felony;
defendant(s) Shazad Khan has a prior serious or violent felony conviction;
defendant(s) Shazad Khan has been convicted of a crime with a Penal Code section 186.11
enhancement;
the crime is not punishable pursuant to Penal Code section 1170(h)(3).

*****
COUNT 3
On or about J uly 8, 2014, in the above named judicial district, the crime of ATTEMPTED
WILLFUL, DELIBERATE, AND PREMEDITATED MURDER, in violation of PENAL CODE
SECTION 664/187(a), a felony, was committed by Shazad Khan, who did unlawfully and with
malice aforethought attempt to murder Mychol Dionne Rayford , a human being.
It is further alleged that the aforesaid attempted murder was committed willfully, deliberately
and with premeditation within the meaning of Penal Code section 664(a) and is a serious felony
pursuant to Penal Code section 1192.7(c).
It is further alleged as to count(s) 2, 3, 4, 5 that said defendant(s) Shazad Khan personally
and intentionally discharged a firearm, a handgun, within the meaning of Penal Code Section
12022.53(c) 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).
It is further alleged as to count(s) 2, 3, 4, 5 that said defendant(s) Shazad Khan personally
used a firearm, a handgun, within the meaning of Penal Code Section 12022.53(b) 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).

It is further alleged that pursuant to Penal Code section 1170(h)(3) defendant(s) Shazad
Khan is eligible for imprisonment in the state prison due to:
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Complaint DA CASE NO: 2014-00-0035724
the current charge is a serious or violent felony;
defendant(s) Shazad Khan has a prior serious or violent felony conviction;
defendant(s) Shazad Khan has been convicted of a crime with a Penal Code section 186.11
enhancement;
the crime is not punishable pursuant to Penal Code section 1170(h)(3).

*****
COUNT 4
On or about J uly 8, 2014, in the above named judicial district, the crime of ATTEMPTED
WILLFUL, DELIBERATE, AND PREMEDITATED MURDER, in violation of PENAL CODE
SECTION 664/187(a), a felony, was committed by Shazad Khan, who did unlawfully and with
malice aforethought attempt to murder J eremy Quwan Mitchell , a human being.
It is further alleged that the aforesaid attempted murder was committed willfully, deliberately
and with premeditation within the meaning of Penal Code section 664(a) and is a serious felony
pursuant to Penal Code section 1192.7(c).
It is further alleged as to count(s) 2, 3, 4, 5 that said defendant(s) Shazad Khan personally
and intentionally discharged a firearm, a handgun, within the meaning of Penal Code Section
12022.53(c) 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).
It is further alleged as to count(s) 2, 3, 4, 5 that said defendant(s) Shazad Khan personally
used a firearm, a handgun, within the meaning of Penal Code Section 12022.53(b) 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).

It is further alleged that pursuant to Penal Code section 1170(h)(3) defendant(s) Shazad
Khan is eligible for imprisonment in the state prison due to:
the current charge is a serious or violent felony;
defendant(s) Shazad Khan has a prior serious or violent felony conviction;
defendant(s) Shazad Khan has been convicted of a crime with a Penal Code section 186.11
enhancement;
the crime is not punishable pursuant to Penal Code section 1170(h)(3).
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Complaint DA CASE NO: 2014-00-0035724

*****
COUNT 5
On or about J uly 8, 2014, in the above named judicial district, the crime of ATTEMPTED
WILLFUL, DELIBERATE, AND PREMEDITATED MURDER, in violation of PENAL CODE
SECTION 664/187(a), a felony, was committed by Shazad Khan, who did unlawfully and with
malice aforethought attempt to murder Austin Lavon Washington , a human being.
It is further alleged that the aforesaid attempted murder was committed willfully, deliberately
and with premeditation within the meaning of Penal Code section 664(a) and is a serious felony
pursuant to Penal Code section 1192.7(c).
It is further alleged as to count(s) 2, 3, 4, 5 that said defendant(s) Shazad Khan personally
and intentionally discharged a firearm, a handgun, within the meaning of Penal Code Section
12022.53(c) 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).
It is further alleged as to count(s) 2, 3, 4, 5 that said defendant(s) Shazad Khan personally
used a firearm, a handgun, within the meaning of Penal Code Section 12022.53(b) 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).

It is further alleged that pursuant to Penal Code section 1170(h)(3) defendant(s) Shazad
Khan is eligible for imprisonment in the state prison due to:
the current charge is a serious or violent felony;
defendant(s) Shazad Khan has a prior serious or violent felony conviction;
defendant(s) Shazad Khan has been convicted of a crime with a Penal Code section 186.11
enhancement;
the crime is not punishable pursuant to Penal Code section 1170(h)(3).

*****
COUNT 6
On or about J uly 8, 2014, in the above named judicial district, the crime of ACCESSORY
AFTER THE FACT-(KNOWLEDGE OF CRIME), in violation of PENAL CODE SECTION 32, a
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Complaint DA CASE NO: 2014-00-0035724
felony, was committed by J effery J erome Bullard J r, who unlawfully, having knowledge that the
crime of Murder, a felony, in violation of Section 187(a) of the Penal Code of the State of California
had been committed by Shazad Khan, did harbor, conceal, and aid said Shazad Khan, with the
intent that he/she might avoid and escape from arrest, trial, conviction, and punishment for said
felony.
It is further alleged that pursuant to Penal Code section 1170(h)(3) defendant(s) J effery
J erome Bullard J r is eligible for imprisonment in the state prison due to:
the current charge is a serious or violent felony;
defendant(s) J effery J erome Bullard J r has a prior serious or violent felony conviction;
defendant(s) J effery J erome Bullard J r has been convicted of a crime with a Penal Code section
186.11 enhancement;
the crime is not punishable pursuant to Penal Code section 1170(h)(3).

*****
It is further alleged pursuant to Penal Code sections 1170.12(a) through (d) and 667(b)
through (i) as to count(s) 6 that said defendant(s) J effery J erome Bullard J r, has suffered the
following prior conviction of a serious or violent felony or juvenile adjudication:

Court Case Code/Statute Conv Date County State Court Type
FVI1001078 PC 186.22(a) 07/20/2010 San Bernardino CA Superior


It is further alleged as to count(s) 6 pursuant to Penal Code section 667.5(b) that the
defendant(s) J effery J erome Bullard J r, has suffered the following prior conviction(s):

Court Case Code/Statute Conv Date County State Court Type
FSB901090 HS 11357(a) 07/20/2010 San Bernardino CA Superior
and that a term was served as described in Penal Code section 667.5 for said offense(s), and that
the defendant(s) did not remain free of prison custody for, and did commit an offense resulting in a
felony conviction during, a period of five years subsequent to the conclusion of said term.

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Complaint DA CASE NO: 2014-00-0035724

* * * * *
NOTICE TO DEFENDANT AND DEFENDANTS 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
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 PERJ URY THAT THE FOREGOING IS TRUE AND
CORRECT AND THAT THIS COMPLAINT CONSISTS OF 6 COUNT(S).
Executed at Rancho Cucamonga, California, on J uly 21, 2014.
D. Schaller
D. Schaller
DECLARANT AND COMPLAINANT

Agency: Rialto Police Department Prelim Est. 00:00

Defendant
J effery J erome Bullard J r
Shazad Khan

Birth Date
09/05/1975
05/20/1991

Booking No.



CII No.
A10661516
A32532275

NCIC




Gang

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Complaint DA CASE NO: 2014-00-0035724