20 a 2 23 24 25 26 27 28 AARON D. FORD Attomey General KELLI R. GALLIMORE (Bar No. 13428) Deputy Attomey General State of Nevada Office of the Attomey General 100N. Carson Stet i Carson City, NV 89701 6 ‘Telephone: (775) 684-1100 ay, - ko Fax: (775) 684-1108 m2 Kgallimore@agav.gov Attorneys for Plaintiff IN THE JUSTICE COURT OF RENO TOWNSHIP IN AND FOR THE COUNTY OF WASHOE, STATE OF NEVADA STATE OF NEVADA, Case No. RCR2020-107334 Plaintiff, Dept. No. vs JEMMA MARIE DAVIS, JUSTIN ANGEL MANLEY, and MASON DYLAN WARD, efondants, CRIMINAL COMPLAINT ‘The undersigned, AARON D. FORD, Attorney General of the State of Nevada, by and through KELLI R. GALLIMORE, Deputy Attorney General, complains and charges the above-named defendants, JEMMA MARIE DAVIS, JUSTIN ANGEL MANLEY, and MASON DYLAN WARD, with having. committed the following offenses: JEMMA MARIE DAVIS has committed the crimes of three (3) counts of TRAFFICKING IN CONTROLLED SUBSTANCES, a category “C” felony in-violation-of NRS-453.3395(1), NRS 195.020; three (3) counts of CONSPIRACY TO VIOLATE THE UNIFORM CONTROLLED SUBSTANCE ACT, a category “C” felony in violation of NRS 453.401(a); three (3) counts of SALE OF A CONTROLLED SUBSTANCE, a category “B” felony in violation of NRS 453.321(1}(a) and (2)(@); one (1) count off POSSESSION OF A CONTROLLED SUBSTANCE, a category “E” felony in violation of NRS 453.336; one (1) count of ELUDING, a category “B” felony in violation of NRS 484B.550(1) and (3)(b); and one uw Page 1 of 7Se ul 12 13 14 16 7 18 20 2 22 23 24 25 26 27 28 (1) count of OBSTRUCTING OR RESISTING A PUBLIC OFFICER, a Category “D” felony in violation] of NRS 199.2802). JUSTIN ANGEL MANLEY has committed the crimes of two (2) counts of TRAFFICKING IN CONTROLLED SUBSTANCES, a category “C” felony in violation of NRS 453.3395(1), NRS 195.020; and two (2) counts of CONSPIRACY TO VIOLATE THE UNIFORM CONTROLLED SUBSTANCE ACT, a category “C” felony in violation of NRS 453.401(a). MASON DYLAN WARD has committed the crimes of one (1) count of TRAFFICKING IN CONTROLLED SUBSTANCES, a category “C” felony in violation of NRS 453.3395(1), NRS 195.020; one (1) count of CONSPIRACY TO VIOLATE THE UNIFORM CONTROLLED SUBSTANCE ACT, a category “C? felony in violation of NRS 453.401(a); and one (1) count of POSSESSION OF A CONTROLLED SUBSTANCE, a category “E” felony in violation of NRS 453.336, COUNTI ‘TRAFFICKING IN CONTROLLED SUBSTANCES Category “C” Felony ~ NRS 453.3395(1); NRS 195.020 ‘That on or about March 20, 2020, the defendants, JEMMA MARIE DAVIS and JUSTIN ANGEL MANLEY, in the County of Washoe, State of Nevada, knowingly or intentionally sold, delivered, brought into the State of Nevada, and/or either actually or constructively, 28 grams or more of a schedule LL controlled substance, or a mixture measuring 28 grams or more and containing a schedule II controlled substance, to wit: approximately 40.0 grams of fentanyl, or a mixture measuring approximately 40.0 grams and containing fentanyl. The defendants, JEMMA MARIE DAVIS and JUSTIN ANGEL MANLEY, being criminally liable under one or more of the following principles of eriminal liability, to wit: (1) by directly committing this crime; and/or (2) by aiding or abetting in the commission of this crime, with the intent that this crime’ be committed, to wit: JEMMA MARIE DAVIS inducing, encouraging, and/or commanding JUSTIN ANGEL MANLEY to possess, and/or deliver, and/or bring into this State, and/or sell said controlled substance and/or provide her with transportation to deliver and/or sell said controlled substance; and/or (3) JEMMA MARIE DAVIS and JUSTIN ANGEL MANLEY conspiring to carry out said acts, uw Page 2 of 71s 16 7 18 19 20 21 22 24 25, 26 27 28 COUNT ‘TRAFFICKING IN CONTROLLED SUBSTANCES Category “C” Felony — NRS 453.3395(1); NRS 195.020 That on or about March 25, 2020, the defendants, JEMMA MARIE DAVIS and JUSTIN ANGEL MANLEY, in the County of Washoe, State of Nevada, knowingly or intentionally sold, delivered, brought into the State of Nevada, and/or either actually or constructively, more than 28 grams of a schedule I controlled substance, or a mixture measuring 28 grams ot more and containing a schedule I controlled substance, to wit: approximately 40.6 grams of fentanyl, or a mixture measuring approximately 40.6 grams ‘and containing fentanyl. 3MMA MARIE DAVIS and JUSTIN ANGEL MANL The defendants, , being criminally liable under one or more of the following principles of criminal liability, to wit: (1) by directly committing this crime; and/or (2) by aiding or abetting in the commission of this crime, with the intent that this crime be committed, by counseling, encouraging, hiring, commanding, inducing and/or otherwise procuring the other to commit the crime, to wit: EMMA MARIE DAVIS inducing, encouraging, commanding, or otherwise procuring JUSTIN ANGEL MANLEY to possess, and/or deliver, and/or bring into this State, and/or sell said controlled substance; and/or (3) JEMMA MARIE DAVIS and JUSTIN ANGEL MANLEY conspiring to carry out said acts. COUNT I TRAFFICKING IN CONTROLLED SUBSTANCES Category “C” Felony — NRS 453.3395(1); NRS 195.020 ‘That on or about April 6, 2020, the defendants, JEMMA MARIE DAVIS and MASON DYLAN WARD, in the County of Washoe, State of Nevada, knowingly or intentionally sold, delivered, brought into the State of Nevada, and/or either actually or constructively, more than 28 grams of a schedule II controlled substance, or a mixture measuring 28 grams or more and containing a schedule II controlled substance, to wit: approximately 47.0 grams of fentanyl, or a mixture measuring approximately 47.0 grams and containing fentanyl ‘The defendants, EMMA MARIE DAVIS and MASON DYLAN WARD, being criminally liable under one or more of the following principles of criminal liability, to wit: (1) by directly committing this Page 3 of 710 u 12 13 4 15 16 7 18 19 20 ai 22 23 24 25 26 oy 28 crime; and/or (2) by aiding or abetting in the commission of this crime, with the intent that this crime be committed, by counseling, encouraging, hiring, commanding, inducing and/or otherwise procuring the other to commit the crime, to wit: JEMMA MARIE DAVIS inducing, encouraging, commanding, ot otherwise procuring MASON DYLAN WARD to possess, and/or deliver, and/or bring into this State, and/or sell said controlled substance; and/or (3) JEMMA MARIE DAVIS and JUSTIN ANGEL MANLEY conspiring to carry out said acts. COUNTIV CONSPIRACY TO VIOLATE THE UNIFORM CONTROLLED SUBSTANCE, Category *C” Felony ~ NRS 453.401(a) ‘That on or about March 20, 2020, the defendants, JEMMA MARIE DAVIS and JUSTIN ANGEL MANLEY, in the County of Washoe, State of Nevada, willfully, unlawfully, and feloniously conspired with each other to commit an offense which is a felony violation of the Uniform Controlled Substance Act, and in furtherance of said conspiracy, the defendants did commit one or more of the acts as set forth in count I, those acts being incorporated by this reference as though fully set forth herein. COUNT V CONSPIRACY TO VIOLATE THE UNIFORM CONTROLLED SUBSTANCE Category “C” Felony ~ NRS 453.401(a) That on or about March 25, 2020, the defendants, JEMMA MARIE DAVIS and JUSTIN ANGEL MANLEY, in the County of Washoe, State of Nevada, willfully, unlawfully, and feloniously conspired with each other to commit an offense which is a felony violation of the Uniform Controlled Substance Act, and in furtherance of said conspiracy, the defendants did commit one or more of the acts as set forth in count II, those acts being incorporated by this reference as though fully set forth herein, c UNT VI CONSPIRACY TO VIOLATE THE UNIFORM CONTROLLED SUBSTANCE Category “C” Felony — NRS 453.401(a) ‘That on or about April 6, 2020, the defendants, JEMMA MARIE DAVIS and MASON DYLAN WARD, in the County of Washoe, State of Nevada, willfully, unlawfully, and feloniously conspired with each other to commit an offense which is a felony violation of the Uniform Controlled Substance Act, and Page 4 of 7in furtherance of said conspiracy, the defendants did commit one or more of the acts as set forth in count II, those acts being incorporated by this reference as though fully set forth herein. COUNT Vit POSSESSION OF A CONTROLLED SUBSTANCE, Category “E” Felony — NRS 453.336 ‘That on or about April 22, 2020, the defendant, JEMMA MARIE DAVIS, in the County of| Washoe, State of Nevada, unlawfully and knowingly or intentionally, possessed a schedule II controlled substance, to wit: approximately 2.2 grams of fentanyl, or a mixture measuring approximately 2.2 grams and containing fentanyl COUNT VIII POS! ‘SION OF A CONTROLLED SUBSTANCE Category “E” Felony — NRS 453.336 ‘That on or about April 22, 2020, the defendant, MASON DYLAN WARD, in the County of| Washoe, State of Nevada, unlawfully and knowingly or intentionally, possessed a schedule I controlled substance, to wit: approximately 2.0 grams of fentanyl, or a mixture measuring approximately 2.0 grams and containing fentanyl. COUNT XI SALE OF A CONTROLLED SUBSTANCE, Category “B” Felony — NRS 453.321 (1)(a) and (2)(a) ‘That on or about February 24, 2020, the defendant, JEMMA MARIE DAVIS, in the County of| Washoe, State of Nevada, unlawfully imported, transported, sold, exchanged, bartered, supplied or gave away a controlled substance, to wit: EMMA MARIE DAVIS sold approximately 2.2 grams of fentanyl or a mixture measuring approximately 2.2 grams and containing fentanyl. COUNT X SALE OF A CONTROLLED SUBSTANCE Category “B” Felony — NRS 453.321 (1)(a) and (2)(a) That on or about March 3, 2020, the defendant, JEMMA MARIE DAVIS, in the County of} Washoe, State of Nevada, unlawfully imported, transported, sold, exchanged, bartered, supplied or gave Page 5 of 7away a controlled substance, to wit: JEMMA MARIE DAVIS sold approximately 16.4 grams of fentanyl, or @ mixture measuring approximately 16.4 grams and containing fentanyl. COUNT XI SALE OF A CONTROLLED SUBSTANCE Category “B” Felony — NRS 453.321 (1)(a) and (2)(a) That on or about March 10, 2020, the defendant, JEMMA MARIE DAVIS, in the County of] Washoe, State of Nevada, unlawfiilly imported, transported, sold, exchanged, bartered, supplied or gave away a controlled substance, to wit: EMMA MARIE DAVIS sold approximately 14.69 grams of fentanyl, or a mixture measuring approximately 14,69 grams and containing fentanyl. COUNT XII ELUDING Category “B” Felony — NRS 4848.550(1) and (3)(b) ‘That on or about April 22, 2020, the defendant, JEMMA MARIE DAVIS, a driver of a motor vehicle on a highway or premise to which the public has access in the County of Washoe, State of Nevada, willfully failed or refused to bring her vehicle to a stop, or otherwise fled or attempted to elude a peace officer in a readily identifiable vehicle of any police department or regulatory agency, when given a signal to bring the vehicle to a stop, and operated the motor vehicle in a manner which endangers or is likely to endanger any other person or the property of any other person, to wit: JEMMA MARIE DAVIS drove over a curb separating a residential property from a public roadway when blocked by four emergency vehicles and/or patrol vehicles with activated lights. JEMMA MARIE DAVIS drove through intersections at speeds in excess of 15 to 20 miles per hour over the posted speed limit of 25 miles per hour, without stopping, despite emergency vehicles and/or patrol vehicles with activated emergency lights and sirens directing her to stop. JEMMA MARIE DAVIS failed to stop at an activated red light, and drove through the same going approximately 25 miles per hour, forcing other vehicles to activate their brakes, almost causing them to strike her vehicle. uw Ww WwW Page 6 of 72 22 23 24 25 26 27 28 OBSTRUCTING OR RESISTING A PUBLIC OFFICER ‘Category “D” Felony — NRS 199.280(2) That on or about April 22, 2020, the defendant, JEMMA MARIE DAVIS, in the County of| Washoe, State of Nevada, willfully resisted, delayed or obstructed a public officer in discharging or attempting to discharge a legal duty of his or her office, to wit: JEMMA MARIE DAVIS resisted the efforts of officers employed by the Federal Bureau of Investigation, and/or other law enforcement agencies, to lawfully arrest her. All of which is contrary to the form, force and effect of the statutes in such cases made and provided, and against the peace and dignity of the state of Nevada. Said Complainant makes this declaration under penalty of perjury. AFFIRMATION PURSUANT TO NRS 239B.030 The undersigned does hereby affirm that the preceding document, CRIMINAL COMPLAINT, filed in the Reno Justice Fe does not contain the social security number of any person. DATED this_“' day of April, 2020, AARON D, FORD Attomey Ggrerat~ >, By: Chiari KECKIRGALLIMORE (Bar No. 13428) Deputy Adogney General Attorney for the State of Nevada Bail: 04/24/2020 $70,000.00 bond posted Justin Bros. Bail Bonds - Davis 04/24/2020 $5,000.00 bond posted Justin Bros. Bail Bonds - Davis {$50,000.00 - Manley $25,000.00 - Ward Page 7 of 7