Superior Court of California County of Sacramento: LLLLLLLLLLLLLLLLLLLL/LLLLLLLLLLLLLLLL /ill
Superior Court of California County of Sacramento: LLLLLLLLLLLLLLLLLLLL/LLLLLLLLLLLLLLLL /ill
1
2 ANNE MARIE SCHUBERT SS0-21-160355
3 DISTRiCT ATTORNEY D. JENSEN, DDA
4 901 G STREET TEAM:CCU
5 SACRAMENTO, CA 95814
6 (916) 874-6218 XRef: 5163300
7
8
9 SUPERIOR COURT OF CALIFORNIA
10
COUNTY OF SACRAMENTO
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12
THE PEOPLE OF THE STATE OF CALIFORNIA, FELONY COMPLAINT
13
14 J.--;A Fir oo 6 '7 '13
vs.
15
16
DEMETRIUS CARL DAVIS, /f)O 13~t-ZL.
17
Defendant.
18 ·---~·--·---·
19
The People of the State of California upon oath of the undersigned, upon information and belief
20
21 complain against the defendant above named for the crime(s) as follows:
22
23 COUNT ONE
24 On or about and between November 20, 2020, and April28, 2021, at and in the County of
25 Sacramento, State of California, the defendant, DEMETRIUS CARL DAVIS, did commit a
26 felony, namely: a violation of Section 288(a) of the Penal Code of the State of California, in that
27 said defendant did willfully, unlawfully, and lewdly commit a lewd and lascivious act, to wit,
28 masturbate his penis until ejaculation at COLEMAN'S direction, upon and with the body and
29 certain parts and members thereof of VINCENT DOE, a child under the age of fourteen years, to
30 wit, age 12 years, with the intent of arousing, appealing to, and gratifying the lust, passions, and
31 sexual desires of the said defendant and the said child.
32
33 "NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
34 1192.7(c)."
35
36 "NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
37 290. Willful failure to register is a crime."
38
39
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4 COUNT TWO
5 For a further and separate cause of action, being a different offense from but connected in its
6 commission as the charges set forth in Count One hereof: On or about and between November
7
20, 2020, and April 28, 2021, at and in the County of Sacramento, State of California, the
8
defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a violation of Section
9
288(a) ofthe Penal Code ofthe State of California, in that said defendant did willfully,
10
11 unlawfully, and lewdly commit a lewd and lascivious act, to wit, masturbate his penis at
12 COLEMAN'S direction, a time different than count one, upon and with the body and certain
13 parts and members thereof of VINCENT DOE, a child under the age of fourteen years, to wit,
14 age 12 years, with the intent of arousing, appealing to, and gratifYing the lust, passions, and
15
sexual desires of the said defendant and the said child.
16
17
18 "NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
19 1192.7(c)."
20
21 "NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
22 290. Willful failure to register is a crime."
23
24
COUNT THREE
25
For a further and separate cause of action, being a different offense from but connected in its
26
commission as the charges set forth in Counts One and Two hereof: On or about and between
27
28 November 20, 2020, and April28, 2021, at and in the County of Sacramento, State of California,
29 the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a violation of Section
30 288(a) of the Penal Code ofthe State of California, in that said defendant did willfully,
31 unlawfully, and lewdly commit a lewd and lascivious act, to wit, masturbate his penis at
32 COLEMAN'S direction, a time different than counts one and two, upon and with the body and
33
certain parts and members thereof of VINCENT DOE, a child under the age of fourteen years, to
34
wit, age 12 years, with the intent of arousing, appealing to, and gratifYing the lust, passions, and
35
36 sexual desires of the said defendant and the said child.
37
38 "NOTICE: The above offense is a serious felony within the meaning ofPenal Code Section
39 1192.7(c)."
40
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"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
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290. Willful failure to register is a crime."
6
7
8 COUNT FOUR
9 For a further and separate cause of action, being a different offense from but connected in its
10 commission as the charges set forth in Counts One through Three hereof: On or about and
11 between March 1, 2021, and December 31, 2021, at and in the County of Sacramento, State of
12 California, the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a
13 violation of Section 288(a) of the Penal Code of the State of California, in that said defendant did
14 willfully, unlawfully, and lewdly commit a lewd and lascivious act, to wit, rubbing her breasts
15 with her hand at COLEMAN'S direction, upon and with the body and certain parts and members
16 thereof of SLOAN DOE, a child under the age of fourteen years, to wit, age 12 years, with the
17 intent of arousing, appealing to, and gratifying the lust, passions, and sexual desires of the said
18 defendant and the said child.
19
20 "NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
21 1192.7(c)."
22
23 "NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
24 290. Willful failure to register is a crime."
25
26 COUNT FIVE
27 For a further and separate cause of action, being a different offense from but connected in its
28 commission as the charges set forth in Counts One through Four hereof: On or about and
29 between March 1, 2021, and December 31, 2021, at and in the County of Sacramento, State of
30 California, the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a
31 violation of Section 288Ca) of the Penal Code of the State of California, in that said defendant did
32 willfully, unlawfully, and lewdly commit a lewd and lascivious act, to wit, rubbing her buttocks
33 with her hand at COLEMAN'S direction, upon and with the body and certain parts and members
34 thereof of SLOAN DOE, a child under the age of fourteen years, to wit, age 12 years, with the
35 intent of arousing, appealing to, and gratifying the lust, passions, and sexual desires of the said
36 defendant and the said child.
37
38 "NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
39
1192.7(c)."
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4 "NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
5 290. Willful failure to register is a crime."
6
7 COUNT SIX
8 For a further and separate cause of action, being a different offense from but connected in its
9 commission as the charges set forth in Counts One through Five hereof: On or about and
10 between March 1, 2021, and December 31, 2021, at and in the County of Sacramento, State of
11 California, the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a
12 violation of Section 288(a) ofthe Penal Code of the State of California, in that said defendant did
13 willfully, unlawfuily, and lewdly commit a lewd and lascivious act, to wit, rubbing her vagina
14 with her hand at COLEMAN'S direction, upon and with the body and certain parts and members
15 thereof of SLOAN DOE, a child under the age of fourteen years, to wit, age 12 years, with the
16 intent of arousing, appealing to, and gratifying the lust, passions, and sexual desires of the said
17 defendant and the said child.
18
19
"NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
20
1192.7(c)."
21
22
"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
23
290. Willful failure to register is a crime."
24
25
COUNT SEVEN
26
For a further and separate cause of action, being a different offense from but connected in its
27
commission as the charges set forth in Counts One through Six hereof: On or about and between
28
March 1, 2021, and December 31,2021, at and in the County of Sacramento, State of California,
29
the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a violation of Section
30
288(a) of the Penal Code ofthe State of California, in that said defendant did willfully,
31
unlawfully, and lewdly commit a lewd and lascivious act, to wit, rubbing her anus with her hand
32
at COLEMAN'S direction, upon and with the body and certain parts and members thereof of
33
SLOAN DOE, a child under the age of fourteen years, to wit, age 12 years, with the intent of
34
35 arousing, appealing to, and gratifying the lust, passions, and sexual desires of the said defendant
37
38 "NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
39 1192.7(c)."
40
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2.
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4 "NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
5 290. Willful failure to register is a crime."
6
7 COUNT TEN
8 For a further and separate cause of action, being a different offense from but connected in its
9 commission as the charges set forth in Counts One through Nine hereof: On or about and
10
between November 12, 2020, and Aprilll, 2021, at and in the County of Sacramento, State of
11
California, the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a
12
13 violation of Section 288(a) of the Penal Code of the State of California, in that said defendant did
14 willfully, unlawfully, and lewdly commit a lewd and lascivious act, to wit, rubbing her vagina
15 with her fingers at COLEMAN'S direction, a time other than count nine, upon and with the body
16 and certain parts and members thereof of LIBERTY DOE, a child under the age of fourteen
17 years, to wit, age 11 years, with the intent of arousing, appealing to; and gratifying the lust,
18
passions, and sexual desires of the said defendant and the said child.
19
20
21 "NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
22 1192.7(c)."
23
24 "NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
25 290. Willful failure to register is a crime."
26
27
COUNT ELEVEN
28
For a further and separate cause of action, being a different offense from but connected in its
29
commission as the charges set forth in Counts One through Ten hereof: On or about and between
30
November 12, 2020, and Aprilll, 2021, at and in the County of Sacramento, State of California,
31
the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a violation of Section
32
288(a) of the Penal Code of the State of California, in that said defendant did willfully,
33
unlawfully, and lewdly commit a lewd and lascivious act, to wit, inserting her finger into her
34
anus at COLEMAN'S direction, upon and with the body and certain parts and members thereof
35
of LIBERTY DOE, a child under the age of fourteen years, to wit, age 11 years, with the intent
36
37 of arousing, appealing to, and gratifYing the lust, passions, and sexual desires of the said
16 violation of Section 288(a) of the Penal Code of the State of California, in that said defendant did
17 willfully, unlawfully, and lewdly commit a lewd and lascivious act, to wit, inserting her finger
18 into her anus at COLEMAN'S direction, a time other than count eleven, upon and with the body
19 and certain parts and members thereof of LIBERTY DOE, a child under the age of fourteen
20
years, to wit, age 11 years, with the intent of arousing, appealing to, and gratifying the lust,
21
passions, and sexual desires of the said defendant and the said child.
22
23
24 "NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
25 1192.7(c)."
26
27
"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
28
290. Willful failure to register is a crime."
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4 COUNT TIDRTEEN
5 For a further and separate cause of action, being a different offense from but connected in its
6 commission as the charges set forth in Counts One through Twelve hereof: On or about and
7 between November 12,2020, and April11, 2021, at and in the County of Sacramento, State of
8 California, the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a
9 violation of Section 288(a) of the Penal Code of the State of California, in that said defendant did
10 willfully, unlawfully, and lewdly commit a lewd and lascivious act, to wit, rubbing her vagina
11 with a toothbrush at COLEMAN'S direction, upon and with the body and certain parts and
12 members thereof of LIBERTY DOE, a child under the age of fourteen years, to wit, age 11
13 years, with the intent of arousing, appealing to, and gratifying the lust, passions, and sexual
14 desires of the said defendant and the said child.
15
16
"NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
17
1192.7(c)."
18
19
"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
20
290. Willful failure to register is a crime."
21
22
COUNT FOURTEEN
23
For a further and separate cause of action, being a different offense from but connected in its
24
commission as the charges set forth in Counts One through Thirteen hereof: On or about and
25
between November 12, 2020, and April11, 2021, at and in the County of Sacramento, State of
26
California, the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a
27
violation of Section 288(a) of the Penal Code of the State of California, in that said defendant did
28
willfully, unlawfully, and lewdly commit a lewd and lascivious act, to wit, rubbing her vagina
29
with a toothbrush at COLEMAN'S direction, a time other than count thirteen, upon and with the
30
body and certain parts and members thereof of LIBERTY DOE, a child under the age of fourteen
31
years, to wit, age 11 years, with the intent of arousing, appealing to, and gratifying the lust,
32
passions, and sexual desires of the said defendant and the said child.
33
34
''NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
35
36 1192.7(c)."
37
38 "NOTICE: Conviction ofthis offense will require you to register pursuant to Penal Code Section
39 290. Willful failure to register is a crime."
40
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4 COUNT FIFTEEN
5 For a further and separate cause of action, being a different offense from but connected in its
6 commission as the charges set forth in Counts One through Fourteen hereof: On or about and
7 between November 4, 2020, and April 2, 2021, at and in the County of Sacramento, State of
8 California, the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a
9 violation of Section 288(a) ofthe Penal Code ofthe State of California, in that said defendant did
10 willfully, unlawfully, and lewdly commit a lewd and lascivious act, to wit, rubbing her vagina
11 with her fingers at COLEMAN'S direction, upon and with the body and certain parts and
12 members thereof of DESTINY DOE, a child under the age of fourteen years, to wit, age 12-13
13 years, with the intent of arousing, appealing to, and gratifying the lust, passions, and sexual
14 desires of the said defendant and the said child.
15
16
"NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
17
1192.7(c)."
18
19
"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
20
290. Willful failure to register is a crime."
21
22
COUNT SIXTEEN
23
For a further and separate cause of action, being a different offense from but connected in its
24
commission as the charges set forth in Counts One through Fifteen hereof: On or about and
25
26 between November 4, 2020, and April2, 2021, at and in the County of Sacramento, State of
27 California, the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a
28 violation of Section 288(a) of the Penal Code of the State of California, in that said defendant did
29 willfully, unlawfully, and lewdly commit a lewd and lascivious act, to wit, rubbing her vagina
30
with her fingers at COLEMAN'S direction, a time other than count fifteen, upon and with the
31
body and certain parts and members thereof of DESTINY DOE, a child under the age of fourteen
32
33 years, to wit, age 12-13 years, with the intent of arousing, appealing to, and gratifying the lust,
34 passions, and sexual desires of the said defendant and the said child.
35
36 "NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
37 1192.7(c)."
38
39
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"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
5
290. Willful failure to register is a crime."
6
7
8 COUNT SEVENTEEN
9 For a further and separate cause of action, being a different offense from but connected in its
10 commission as the charges set forth in Counts One through Sixteen hereof: On or about and
11 between November 4, 2020, and April 2, 2021, at and in the County of Sacramento, State of
12 California, the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a
13 violation of Section 288(a) of the Penal Code ofthe State of California, in that said defendant did
14 willfully, unlawfully, and lewdly commit a lewd and lascivious act, to wit, rubbing her vagina
15 with her fingers at COLEMAN'S direction, a time other than counts fifteen and sixteen, upon
16 and with the body arid certain parts and members thereof of DESTINY DOE, a child under the
17 age of fourteen years, to wit, age 12-13 years, with the intent of arousing, appealing to, and
18 gratifying the lust, passions, and sexual desires of the said defendant and the said child.
19
20 "NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
21 1192.7(c)."
22
23 "NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
24 290. Willful failure to register is a crime."
25
26 COUNT EIGHTEEN
27 For a further and separate cause of action, being a different offense from but connected in its
28 commission as the charges set forth in Counts One through Seventeen hereof: On or about and
29 between November 4, 2020, and April2, 2021, at and in the County of Sacramento, State of
30 California, the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a
31 violation of Section 288(a) of the Penal Code of the State of California, in that said defendant did
32 willfully, unlawfully, and lewdly commit a lewd and lascivious act, to wit, rubbing her vagina
33 with a toothbrush at COLEMAN'S direction, upon and with the body and certain parts and
34 members thereof of DESTINY DOE, a child under the age offourteen years, to wit, age 12-13
35 years, with the intent of arousing, appealing to, and gratifying the lust, passions, and sexual
36 desires of the said defendant and the said child.
37
38 "NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
39
1192.7(c)."
40
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4 "NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
5 290. Willful failure to register is a crime."
6
7 COUNT NINETEEN
8 For a further and separate cause of action, being a different offense from but connected in its
9 commission as the charges set forth in Counts One through Eighteen hereof: On or about and
10 between November 4, 2020, and April 2, 2021, at and in the County of Sacramento, State of
11 California, the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a
12 violation of Section 288(a) of the Penal Code of the State of California, in that said defendant did
13 willfully, unlawfully, and lewdly commit a lewd and lascivious act, to wit, rubbing her vagina
14 with a toothbrush at COLEMAN'S direction, a time other than count eighteen, upon and with the
15 body and certain parts and members thereof of DESTINY DOE, a child under the age of fourteen
16 years, to wit, age 12-13 years, with the intent of arousing, appealing to, and gratifying the lust,
17
passions, and sexual desires of the said defendant and the said child.
18
19
"NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
20
1192.7(c)."
21
22
"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
23
290. Willful failure to register is a crime."
24
25
COUNT TWENTY
26
For a further and separate cause-of action, being a different offense from but connected in its
27
commission as the charges set forth in Counts One through Nineteen hereof: On or about and
28
between April 24, 2021, and August 26, 2021, at and in the County of Sacramento, State of
29
California, the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a
30
violation of Section 288(a) of the Penal Code ofthe State of California, in that said defendant did
31
willfully, unlawfully, and lewdly commit a lewd and lasdvious act, to wit, rubbing her vagina
32
with her fingers at COLEMAN'S direction, upon and \Vith the body and certain parts and
33
members thereof of MACI DOE, a child under the age of fourteen years, to wit, age 10 years,
34
35 with the intent of arousing, appealing to, and gratifying the lust, passions, and sexual desires of
37
38 "NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
39 1192.7(c)."
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4 "NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
5 290. Willful failure to register is a crime."
6
7 COUNT TWENTY"ONE
8 For a further and separate cause of action, being a different offense from but connected in its
9 commission as the charges set forth in Counts One through Twenty hereof: On or about and
10 between April 24, 2021, and August 26, 2021, at and in the County of Sacramento, State of
11 California, the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a
12 violation of Section 288(a) of the Penal Code ofthe State of California, in that said defendant did
13 willfully, unlawfully, and lewdly commit a lewd and lascivious act, to wit, inserting her finger
14 into her vagina at COLEMAN'S direction, upon and with the body and certain parts and
15 members thereof of MACI DOE, a child under the age of fourteen years, to wit, age 10 years,
16 with the intent of arousing, appealing to, and gratifying the lust, passions, and sexual desires of
17
the said defendant and the said child.
18
19
"NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
20
1192.7(c)."
21
22
"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
23
290. Willful failure to register is a crime."
24
25
COUNT TWENTY" TWO
26
For a further and separate cause of action, being a different offense from but connected in its
27
commission as the charges set forth in Counts One through Twenty-One hereof: On or about and
28
between April24, 2021, and August 26, 2021, at and in the County of Sacramento, State of
29
California, the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a
30
violation of Section 288(a) ofthe Penal Code of the State of California, in that said defendant did
31
willfully, unlawfully, and lewdly commit a lewd and lascivious act, to wit, inserting her finger
32
into her vagina at COLEMAN'S direction, a time other than count twenty-one, upon and with
33
the body and certain parts and members thereof ofMACI DOE, a child under the age offourteen
34
years, to wit, age 10 years, with the intent of arousing, appealing to, and gratifying the lust,
35
36 passions, and sexual desires of the said defendant and the said child.
37
38 "NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
39 1192.7(c)."
40
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4 "NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
5 290. Willful failure to register is a crime."
6
7 COUNT TWENTY-THREE
8 For a further and separate cause of action, being a different offense from but connected in its
9 commission as the charges set forth in Counts One through Twenty-Two hereof: On or about and
10 between April 24, 2021, and August 26, 2021, at and in the County of Sacramento, State of
11 California, the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a
12 violation of Section 288(a) of the Penal Code of the State of California, in that said defendant did
13 willfully, unlawfully, and lewdly commit a lewd and lascivious act, to wit, inserting her finger
14 into her anus at COLEMAN'S direction, upon and with the body and certain parts and members
15 thereof of MAC! DOE, a child under the age of fourteen years, to wit, age 10 years, with the
16
intent of arousing, appealing to, and gratifying the lust, passions, and sexual desires of the said
17
defendant and the said child.
18
19
"NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
20
1192.7(c).tt
21
22
"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
23
290. Willful failure to register is a crime.••
24
25
COUNT TWENTY-FOUR
26
For a further and separate cause of action, being a different offense from but connected in its
27
commission as the charges set forth in Counts One through Twenty-Three hereof: On or about
28
and between October 11, 2021, and December 24, 2021, at and in the County of Sacramento,
29
State of California, the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a
30
violation of Section 288(a) of the Penal Code of the State of California, in that said defendant did
31
willfully, unlawfully, and lewdly commit a lewd and lascivious act, to wit, inserting her finger
32
into her vagina at COLEMAN'S direction, upon and with the body and certain pru1s and
33
members thereof of GUARISSA DOE, a child under the age of fourteen years, to wit, age 9
34
years, with the intent of arousing, appealing to, and gratifying the lust, passions, at1d sexual
35
36 desires of the said defendant and the said child.
37
38 "NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
39 1192.7(c)."
40
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41 1239583
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2
3
4 "NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
5 290. Willful failure to register is a crime."
6
7 COUNT TWENTY-FIVE
8 For a further and separate cause of action, being a different offense from but connected in its
9 commission as the charges set forth in Counts One through Twenty-Four hereof: On or about and
10 between October 11,2021, and December 24,2021, at and in the County of Sacramento, State of
11 California, the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a
12 violation of Section 288(a) of the Penal Code of the State of California, in that said defendant did
13 willfully, unlawfully, and lewdly commit a lewd and lascivious act, to wit, inserting her finger
14 into her vagina at COLEMAN'S direction, a time other than count twenty-four, upon and with
15 the body and certain parts and members thereof of GUARISSA DOE, a child under the age of
16 fourteen years, to wit, age 9 years, with the intent of arousing, appealing to, and gratifying the
17 lust, passions, and sexual desires of the said defendant and the said child.
18
19
"NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
20
1192.7(c)."
21
22
"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
23
290. Willful failure to register is a crime."
24
25
COUNT TWENTY-SIX
26
For a further and separate cause of action, being a different offense from but connected in its
27
commission as the charges set forth in Counts One through Twenty-Five hereof: On or about and
28
between October 11,2021, and December 24,2021, at and in the County of Sacramento, State of
29
California, the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a
30
violation of Section 288(a) of the Penal Code of the State of California, in that said defendant did
31
willfully, unlawfully, and lewdly commit a lewd and lascivious act, to wit, inserting her finger
32
into her anus at COLEMAN'S direction, upon and with the body and certain parts and members
33
thereof of GU ARISSA DOE, a child under the age of fourteen years, to wit, age 9 years, with the
34
· intent of arousing, appealing to, and gratifying the lust, passions, and sexual desires of the said
35
36 defendant and the said child.
37
38 "NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
39 1192.7(c)."
40
14 1111111111111111111~11~1111~11111111111111
41 1239583
1
2
3
4 "NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
5 290. Willful failure to register is a crime."
6
7 COUNT TWENTY-SEVEN
8 For a further and separate cause of action, being a different offense from but connected in its
9 commission as the charges set forth in Counts One through Twenty-Six hereof: On or about and
10 between October 11,2021, and December 24,2021, at and in the County of Sacramento, State of
11 California, the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a
12 violation of Section 288(a) of the Penal Code of the State of California, in that said defendant did
13 willfully, unlawfully, and lewdly commit a lewd and lascivious act, to wit, inserting her finger
14 into her anus at COLEMAN'S direction, a time other than count twenty-six, upon and with the
15 body and certain parts and members thereof of GUARISSA DOE, a child under the age of
16 fourteen years, to wit, age 9 years, with the intent of arousing, appealing to, and gratifying the
17 lust, passions, and sexual desires of the said defendant and the said child.
18
19
"NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
20 1192.7(c)."
21
22
"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
23
290. Willful failure to register is a crime."
24
25
COUNT TWENTY-EIGHT
26
For a further and separate cause of action, being a different offense from but connected in its
27
commission as the charges set forth in Counts One through Twenty-Seven hereof: On or about
28
29 and between October 11, 2021, and December 24, 2021, at and in the County of Sacramento,
30 State of California, the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a
31 violation of Section 288(a) of the Penal Code of the State of California, in that said defendant did
32 willfully, unlawfully, and lewdly commit a lewd and lascivious act, to wit, Surya Doe touching
33
Guarissa Doe's vagina with his hand at COLEMAN'S direction, upon and with the body and
34
certain parts and members thereof of GUARISSA DOE, a child under the age of fourteen years,
35
to wit, age 9 years, with the intent of arousing, appealing to, and gratifying the lust, passions, and
36
37 sexual desires of the said defendant and the said child.
38
39
40
15 lllllllllllllllllll!llll~llllll mn1111111
41 1239583
,Q ··0
1
2
3
4
"NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
5
1192.7(c)."
6
7
8 "NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
9 290. Willful failure to register is a crime. 11
10
11 COUNT TWENTY-NINE
12 For a further and separate cause of action, being a different offense from but connected in its
13 commission as the charges set forth in Counts One through Twenty-Eight hereof: On or about
14 and between October 11,2021, and December 24, 2021, at and in the County of Sacramento,
15 State of California, the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a
16 violation of Section 288(a) of the Penal Code of the State of California, in that said defendant did
17 willfully, unlawfully, and lewdly commit a lewd and lascivious act, to wit, Surya Doe touching
18
his penis to Guarissa Doe's vagina at COLEMAN'S direction, upon and with the body and
19
certain parts and members thereof of GUARISSA DOE, a child under the age of fourteen years,
20
to wit, age 9 years, with the intent of arousing, appealing to, and gratifying the lust, passions, and
21
sexual desires of the said defendant and the said child.
22
23
"NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
24
1192.7(c)."
25
26
"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
27
290. Willful failure to register is a crime."
28
29
30
31
32
33
34
35
36
37
38
39
40
16 11111111111111111 m111~11 mllllllllllllll
41 1239583
0
1
2
3
4 COUNT THIRTY
5 For a further and separate cause of action, being a different offense from but connected in its
6 commission as the charges set forth in Counts One through Twenty-Nine hereof: On or about
7 and between October II, 202I, and December 24, 202I, at and in the County of Sacramento,
8 State of California, the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a
9 violation of Section 288(a) of the Penal Code of the State of California, in that said defendant did
10 willfully, unlawfully, and lewdly commit a lewd and lascivious act, to wit, Guarissa Doe putting
11 her mouth to Surya Doe's penis at COLEMAN'S direction, upon and with the body and certain
12 parts and members thereof of SURYA DOE, a child under the age of fourteen years, to wit, age 6
13 years, with the intent of arousing, appealing to, and gratifying the lust, passions, and sexual
14 desires of the said defendant and the said child.
15
16 "NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
17 Il92.7(c)."
18
19
"NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
20
290. Willful failure to register is a crime."
21
22
COUNTTIDRTY-ONE
23
For a further and separate cause of action, being a different offense from but connected in its
24
commission as the charges set forth in Counts One through Thirty hereof: On or about and
25
between October 11,2021, and December 24,2021, at and in the County of Sacramento, State of
26
California, the defendant, DEMETRIUS CARL DAVIS, did commit a felony, namely: a
27
violation of Section 288(a) of the Penal Code of the State of California, in that said defendant did
28
willfully, unlawfully, and lewdly commit a lewd and lascivious act, to wit, Guarissa Doe putting
29
her mouth to Surya Doe's penis at COLEMAN'S direction, a time other than count thirty, upon
30
and with the body and certain parts and members thereof of SURYA DOE, a child under the age
31
of fourteen years, to wit, age 6 years, with the intent of arousing, appealing to, and gratifying the
32
lust, passions, and sexual desires of the said defendant and the said child.
33
34
"NOTICE: The above offense is a serious felony within the meaning of Penal Code Section
35
36 1192.7(c)."
37
38 "NOTICE: Conviction of this offense will require you to register pursuant to Penal Code Section
19 1192.7(c)."
20
21 "NOTICE: Conviction ofthis offense will require you to register pursuant to Penal Code Section
22 290. Willful failure to register is a crime."
23
24
It is further alleged that the defendant, DEMETRIUS CARL DAVIS, has been convicted in the
25
present case or cases of committing an offense specified in subdivision (c) against more than one
26
27 victim, within the meaning of Penal Code Section 667.6l(e)(4) and 667.610)(2).
28
29 It is further alleged that in the commission of the above offense(s), the defendant, DEMETRIUS
30 CARL DAVIS, committed the above offense on more than one victim, within the meaning of
31 Penal Code Section 1203.066(a)(7).
32
33 It is further alleged that in the commission of the above offense the defendant, DEMETRIUS
34 CARL DAVIS, is a person who, in violating Section 288 or Section 288.5 of the Penal Code, has
35 substantial sexual contact with a victim who is under the age of fourteen years old, within the
36 meaning of Penal Code Section 1203.066(a)(8).
37
38
39
40
41
18 lllllllllllllllllllllllllllllllllllllllllllll
1239583
0 ··0
1
2
3
4
It is further alleged that in the commission of the above offense the defendant, DEMETRIUS
5
6 CARL DAVIS, used obscene matter and matter depicting sexual conduct within the meaning of