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KhanComplaint February 17
KhanComplaint February 17
KhanComplaint February 17
Superior Court
Case No: STK-CR-FE-2023-0002047
Date: 02/15/2023
1 RONALD J. FREITAS
District Attorney, County of San Joaquin By: Joseph Montanez
2 State Bar Number 135885
By: Donald Vaughn, SBN 232955
3 Deputy District Attorney
222 E. Weber Avenue, First Floor, Room 101,
4 P.O. Box 990
Stockton, California 95201
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Telephone: (209) 468-2400
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Attorneys for Plaintiff
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I, the undersigned, say, on information and belief, that in the County of SAN JOAQUIN, State
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of California:
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COUNT 1: Code Section EL 18100(A) CAUSING/PROCURING/ALLOWING FALSE
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VOTER REGISTRATION OF SELF/ANOTHER PERSON
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On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,
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SHAKIR KHAN did did commit the crime of CAUSING/PROCURING/ALLOWING FALSE
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VOTER REGISTRATION OF SELF/ANOTHER PERSON, in violation of Section 18100(a)
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of the Elections Code, a FELONY, who at the time and place last aforesaid, did willfully cause,
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procure, and allow themselves/any other person to be registered as a voter, and acted knowing
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AW
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1
1 themselves/another person are not entitled to this voter registration, to wit: VARIOUS
2 INDIVIDUALS.
4 For a further and separate cause of complaint, being a different offense from but connected in
5 its commission with the charge(s) above, complainant further complains and says:
9 On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,
12 Section 18101 of the Elections Code, a FELONY, who at the time and place last aforesaid, did
13 willfully and knowingly complete, procure the completion of, in whole and in part, an affidavit
14 of registration and voter registration card, with the intent to cause the registration or
15 reregistration as a voter of a fictitious person and any person who had not requested registration
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18 For a further and separate cause of complaint, being a different offense from but connected in
19 its commission with the charge(s) above, complainant further complains and says:
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22 NOMINATION PETITION
23 On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,
24 SHAKIR KHAN did did commit the crime of SUBSCRIPTION OF FICTITIOUS NAME TO
26 who at the time and place last aforesaid, did willfully and knowingly subscribe, cause another
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1 to subscribe, a fictitious name to any nomination petition, and acted with the intent to subscribe
4 For a further and separate cause of complaint, being a different offense from but connected in
5 its commission with the charge(s) above, complainant further complains and says:
8 NOMINATION PETITION
9 On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,
10 SHAKIR KHAN did did commit the crime of SUBSCRIPTION OF FICTITIOUS NAME TO
12 who at the time and place last aforesaid, did willfully and knowingly subscribe, cause another
13 to subscribe, a fictitious name to any nomination petition, and acted with the intent to subscribe
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16 For a further and separate cause of complaint, being a different offense from but connected in
17 its commission with the charge(s) above, complainant further complains and says:
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20 NOMINATION PETITION
21 On or about June 1, 2020 to November 3, 2020,in the County of San Joaquin, California,
22 SHAKIR KHAN did did commit the crime of SUBSCRIPTION OF FICTITIOUS NAME TO
24 who at the time and place last aforesaid, did willfully and knowingly subscribe, cause another
25 to subscribe, a fictitious name to any nomination petition, and acted with the intent to subscribe
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3
1 For a further and separate cause of complaint, being a different offense from but connected in
2 its commission with the charge(s) above, complainant further complains and says:
5 NOMINATION PETITION
6 On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,
7 SHAKIR KHAN did did commit the crime of SUBSCRIPTION OF FICTITIOUS NAME TO
9 who at the time and place last aforesaid, did willfully and knowingly subscribe, cause another
10 to subscribe, a fictitious name to any nomination petition, and acted with the intent to subscribe
12 For a further and separate cause of complaint, being a different offense from but connected in
13 its commission with the charge(s) above, complainant further complains and says:
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15 For a further and separate cause of complaint, being a different offense from but connected in
16 its commission with the charge(s) above, complainant further complains and says:
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19 NOMINATION PETITION
20 On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,
21 SHAKIR KHAN did did commit the crime of SUBSCRIPTION OF FICTITIOUS NAME TO
23 who at the time and place last aforesaid, did willfully and knowingly subscribe, cause another
24 to subscribe, a fictitious name to any nomination petition, and acted with the intent to subscribe
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1 For a further and separate cause of complaint, being a different offense from but connected in
2 its commission with the charge(s) above, complainant further complains and says:
5 NOMINATION PETITION
6 On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,
7 SHAKIR KHAN did did commit the crime of SUBSCRIPTION OF FICTITIOUS NAME TO
9 who at the time and place last aforesaid, did willfully and knowingly subscribe, cause another
10 to subscribe, a fictitious name to any nomination petition, and acted with the intent to subscribe
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13 For a further and separate cause of complaint, being a different offense from but connected in
14 its commission with the charge(s) above, complainant further complains and says:
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17 NOMINATION PETITION
18 On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,
19 SHAKIR KHAN did did commit the crime of SUBSCRIPTION OF FICTITIOUS NAME TO
21 who at the time and place last aforesaid, did willfully and knowingly subscribe, cause another
22 to subscribe, a fictitious name to any nomination petition, and acted with the intent to subscribe
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25 For a further and separate cause of complaint, being a different offense from but connected in
26 its commission with the charge(s) above, complainant further complains and says:
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1 COUNT 10: Code Section EL 18203 FALSE NOMINATION/DECLARATION OF
2 CANDIDACY
3 On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,
5 CANDIDACY, in violation of Section 18203 of the Elections Code, a FELONY, who at the
6 time and place last aforesaid, did willfully and knowingly file, submit for filing, a nomination
7 paper/declaration of candidacy, which is in whole and in part false, to wit: JOHN or JANE
8 DOE.
10 For a further and separate cause of complaint, being a different offense from but connected in
11 its commission with the charge(s) above, complainant further complains and says:
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14 CANDIDACY
15 On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,
17 CANDIDACY, in violation of Section 18203 of the Elections Code, a FELONY, who at the
18 time and place last aforesaid, did willfully and knowingly file, submit for filing, a nomination
19 paper/declaration of candidacy, which is in whole and in part false, to wit: JOHN or JANE
20 DOE.
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22 For a further and separate cause of complaint, being a different offense from but connected in
23 its commission with the charge(s) above, complainant further complains and says:
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26 On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,
27 SHAKIR KHAN did did commit the crime of FRAUDULENT CASTING OF VOTES, in
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1 violation of Section 18500 of the Elections Code, a FELONY, who at the time and place last
2 aforesaid, did willfully commit fraud, attempt to commit fraud, aid/abet fraud, attempt to
3 aid/abet fraud, in connection with any vote cast, attempted to be cast, and to be cast in the
6 For a further and separate cause of complaint, being a different offense from but connected in
7 its commission with the charge(s) above, complainant further complains and says:
11 TO VOTE
12 On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,
15 VOTE, in violation of Section 18561(a) of the Elections Code, a FELONY, who at the time
16 and place last aforesaid, did willfully and knowingly procure, assist, counsel, advise another
17 person to give and offer their vote at any election when that other person is not qualified to vote
18 in said election.
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20 For a further and separate cause of complaint, being a different offense from but connected in
21 its commission with the charge(s) above, complainant further complains and says:
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24 FRAUDULENT VOTING
25 On or about June 1, 2020 to November 3, 2020, in the County of San Joaquin, California,
26 SHAKIR KHAN did did commit the crime of AIDING AND ABETTING COMMISSION OF
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1 FELONY, who at the time and place last aforesaid, did willfully aid and abet in the fraudulent
2 casting of a vote.
4 If the above-named defendant(s) is/are presently on probation in San Joaquin County, any
5 evidence presented at a preliminary hearing in the instant case will be used not only as a basis
6 for a holding order in this case but also as evidence of a violation of probation and, at any
7 formal hearing on that violation of probation, the People will move the transcript of the
10 That attached hereto and by this reference incorporated herein is a declaration setting forth
11 facts in support of probable cause for the issuance of warrant of arrest herein.
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13 Pursuant to Penal Code Section 1054.5(b), the People hereby informally request that the
14 defendant and their attorney disclose to the People all information and materials described in
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17 I declare under penalty of perjury that the foregoing is true and correct except for those things
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DONALD VAUGHN
23 Deputy District Attorney
DV/mm
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