16 7 18 19 2 23 24 25 STEPHEN M. WAGSTAFFE, DISTRICT ATTORNEY County of San Matco, State of California State Bar No, 78470 400 County Center, Third Floor Redwood City, CA 94063 By: Stephen M. Wagstaffe, District Attomey Telephone: (650) 363-4636 Attomey for Plaintit? IN THE SUPERIOR COURT OF THE STATE OF CALIFORNIA. IN AND FOR THE COUNTY OF SAN MATEO} ‘THE PEOPLE OF THE STATE OF CALIFORNIA | REPORT NO}S02300605 & 802300617 Plaintiff, DA CASE NO, 0877541 vs FEL ay 4A Patan 23SF00158 12761 SAN MATEO RD HALF MOON BAY, CA 94019 I, the undersigned, say, on information and belief, that in the oun of San Mateo, State of pf peti at a ines California: COUNT 1: PC187(a) (Felony) On or about January 23, 2023, in the County of San Mateo, State of California, the crime of Murder in violation of PC187(a), a Felony, was committed in that CHUNL] ZHAO did unlawfully, and with malice aforethought murder Qi Zhong Cheng, a human being.20 21 >) 25 NOTICE: The above offense is a serious felony within the meaning 1192.7(c) and a violent felony within the meaning of Penal Code Section 66 ENHANCEMENT 1 if Penal Code Section IO) PC12022.53(d): Special Allegation-Personal And Intentional Discharge Of A Firearm Causing Death It is further alleged as to Count J that said defendant, CHUNLI ZHAD personally and. intentionally discharged a firearm, a handgun, which caused deathi to Qi Zhang Cheng within the meaning of Penal Code Section 12022,53(d) also causing the above offense felony pursuant to Penal Code section 1192.7(c)(8) and a violent felony wit Code section 667.5(6)(8). ENHANCEMENT 2 PC1203.075(a): Special Allegation- Great Bodily Ta Itis further alleged as to Count 1 that in the commission of the abo defendant, CHUNLI ZHAO personally inflicted great bodily injury upon Qi to become a serious in the meaning of Penal fury offense the said Zhong Cheng, not an accomplice to the above offense, within the meaning of Penal Code Sections 1203.075(a) and 12022.7. COUNT 2: PC187(a) (Felony) On or about January 23, 2023, in the County of San Mateo, State o ‘California, the crime of Murder in violation of PC187(a), a Felony, was committed in that CHUNLL ZHAO did unlawfully, and with malice aforethought murder Ye Tao Bing, a human being.21 22 23 25 NOTICE: The above offense is a serious felony within the meaning 1192.7(c) and a violent felony within the meaning of Penal Code Section 66] ENHANCEMENT 1 PC12022,53(d): Special Allegation-Personal And Intentional Discharge Death Penal Code Section 5(e) Df A Firearm Causing Ttis further alleged as to Count 2 that said defendant, CHUNLI ZHAO personally and intentionally discharged a firearm, a handgun, which caused death to Ye Tas i Bing within the of Penal Code Section 12022.53(d) also causing the above offense po become a serious felony pursuant to Penal Code section 1192.7(c)(8) atid violgit felony Within the meaning of Penal 4 Code section 667.5(c)(8). ENHANCEMENT 2 PC1203.075(a): Special Allegation-Great Bodily Iugury It is further alleged as to Count 2 that in the commission of the above offense the said defendant, CHUNLI ZHAO personally inflicted great bodily injury upon ¥} r Tao Bing, not an accomplice to the above offense, within the meaning of Penal Code Sections 1203.075(a) and 1202.7. COUNT 3: PC187(a) (Felony) On or about January 23, 2023, in the County of San Mateo, State o! California, the crime of Murder in violation of PC187(a), a Felony, was committed in that CHUNLf ZHAO did unlawfully, and with malice aforethought murder Jing Zhi Lu, a human being.14 15 16 7 18 19 20 21 2B 24 25 NOTICE: The above offense is a serious felony within the meaning df 1192.7(¢) and a violent felony within the meaning of Penal Code Section 66 sna tbondhe A 4 Penal Code Section 5() PC12022.53(a): Spectal Allegation-Personal And Intentional Dischargd Of A Firearm Causing Death Itis further alleged as to Count 3 that said defendant, CHUNLI ZHAO personally and intentionally discharged a firearm, a handgun, which caused death to Jing Zisi Lu 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 fneaning of Penal Code section 667.5(c)(8). } ENHANCEMENT 2 PC1203.075(a): Special Allegation-Great Bodily Inj jury It is further alleged as to Count 2 that in the commission of the above offense the said defendant, CHUNLI ZHAO personally inflicted great bodily injury upon Ji 1g Zhi Lu, not an accomplice to the above offense, within the meaning of Penal Code Sectiorts 1203.075(a) and 12022.7. COUNT 4: PC187(a) (Felony) On or about January 23, 2023, in the County of San Mateo, State of Murder in violation of PC187(a), a Felony, was committed in that CHUNL and with malice aforethought murder Jose Romero Perez, a human being.’ | é ‘¥ ‘California, the crime of ZHAO did unlawfully,17 18 19 20 21 22 23 25 NOTICE: The above offense is a serious felony within the meaning 1192.7(¢) and a violent felony within the meaning of Penal Code Section 66 ENHANCEMENT 1 PC12022,53(d): Special Allegation-Personal And Intentional Discharge Death ‘Penal Code Section -5(c) fA Firearm Causing Itis further alleged as to Count 4 that said defendant, CHUNLI ZHAD personally and intentionally discharged a firearm, a handgun, which caused death to Jose Romero Perez within the meaning of Penal Code Section 12022.53(d) also causing the above offense felony pursuant to Penal Code section 1192.7(c)(8) and a violent felony wit Code section 667.5(c)(8). ENHANCEMENT 2 become a serious the meaning of Penal PC1203.075(a): Special Alegation-Great Bodily Injury It is further alleged as to Count 4 that in the commission of the =f offense the said defendant, CHUNLI ZHAO personally inflicted great bodily injury ifpon J e Romero Perez, not an accomplice to the above offense, within the meaning of Penal Code Sections 1203.075(a) and 1202.7. COUNT 5: PC664/PC187(a) (Felony) On or about January 23, 2023, in the County of San Mateo, State of California, the crime of Attempted Willful, Deliberate, And Premeditated Murder in violation of Pt ©664/PC187(a), a Felony, was committed in that CHUNLI ZHAO did unlawfully and with malice aferethought attempt to murder Pedro Romero Perez, a human being.13 14 1S 16 7 18 19 20 21 22 23 25 It is further alleged that the aforesaid attempted murder-was committed willfully, deliberately.and with premeditation within the meaning of Penal Code section 189. NOTICE: The above offense is a serious felony within the meaning of Penal Code Section 1192.7(¢) and a violent felony within the meaning of Penal Code Section 66 ENHANCEMENT 1 PC12022.53(d): Special Allegation-Personal And Intentional Discharge Great Bodily Injury t Itis further alleged as to Count 5 that said defendant, CHUNLI ZHAS intentionally discharged a firearm, a handgun, which caused great bodily inj Perez within the meaning of Penal Code Section 12022.53(d) also causing 5(C)- Of A Firearm Causing personally and ry to Pedro Romero 1e above offense to become a serious felony pursuant to Penal Code section 1192.7(c)(8) and a piolent felony within the meaning of Penal Code section 667.5(c)(8)- COUNT 6: PC187(a) (Felony) On or about January 23, 2023, in the County of San Mateo, State oftCalifornia, the crime of Murder in violation of PC187(a), a Felony, was committed in that CHUNL} and with malice aforethought murder Marciano Jimenez Martinez, a humay ZHAO did unlawfully, 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 6 57.5(c)1 2 16 17 18 19 20 2 22 23 24 25 ENHANCEMENT 1 PC12022,83(d): Special Allegation-Personal And Intentional, fighargeor A Rirearm Causing Death It is further alleged as to Count 6 that said defendant, CHUNLI ZHAD personally and intentionally discharged a firearm, a handgun, which caused death to Marcigno Jimenez Martinez within the meaning of Penal Code Section 12022.53(d) also causing the aboy= offense to become a serious felony pursuant to Penal Code section 1192.7(c)(8) and a violent feldny within the meaning of Penal Code section 667.5(c)(8). ENHANCEMENT 2 PC1203.075(a): Special Allegation-Great Bodily Injury It is further alleged as to Count 6that in the commission of the abovg offense the said defendant, CHUNLI ZHAO personally inflicted great bodily injury upon Mpreiano Jimenez Martinez, not an accomplice to the above offense, within the meaning of Peal Code Sections 1203.075(a) and 12022.7. COUNT 7: PC187(a) (Felony) On or about January 23, 2023, in the County of San Mateo, State offCalifornia, the crime of Murder in violation of PC187(a), a Felony, was committed in that CHUNL] and with malice aforethought murder Zhi Shen Liu, a human being. © ZHAO did unlawfully, NOTICE: The above offense is a serious felony within the meaning of Penal Code Section 1192,7(c) and a violent felony within the meanirly of Penal Code Section €} R7.S(C)n 7 18 19 20 2 23 24 25 ENHANCEMENT 1 PC12022.S4 A): Special Allegation-Personal And Intentional Discharge! pr Death Itis further alleged as to Count 7 that said defendant, CHUNLI ZHAG personally and intentionally discharged a firearm, a handgun, which caused death to Zhi Sh¢a Liu within the meaning of Penal Code Section 12022.53(d) also causing the above offense fo become a serious felony pursuant to Penal Code scetion 1192,7(c)(8) and a violent felony witlin the meaning of Penal Code section 667.5(€)(8). ENHANCEMENT 2 PC1203.075(a): Special Allegation-Great Bodily Injary It is further alleged as to Count 7 that in the commission of the above offense the said éefendant, CHUNLI ZHAO personally inflicted great bodily injury upon Ziti Shen Liu, not an accomplice to the above offense, within the meaning of Penal Code Sectiors 1203.075(a) and 1202.7. COUNT 8: PC187(a) (Felony) On or about January 23, 2023 at 4:41 PM, in the County of San Mako, crime of Murder in violation of PC187(a), a Felony, was committed in that]CHUNLI ZHAO did unlawfully, and with malice aforethought murder Ai Xiang Zhang, a humes being. NOTICE: The above offense is a serious felony within the =p Code Section 1192.7(c) and a violent felony within the meaning of Penal Code Section ‘A Firearm Causing , State of California, the .5(C)1 ENHANCEMENT 1 2] Pc12022.s3(4): Special Allegation-Personal And Intentional Discharge Of A Firearm Causing . Death 4 [tis further alleged as to Count 8 that said defendant, CHUNLI ZHAD personally and intentionally discharged a firearm, a handgun, which caused death to Ai Xiang Zhang within the meaning of Penal Code Section 12022.53(d) also causing the above offense fo become a serious 7 | felony pursuant to Penal Code section 1192.7(c)(8) and a violent felony within the meaning of Penal 8 ] Code section 667.5(c)(8). 9 10 ENHANCEMENT 2 n PC1203.075(a): Special Allegation-Great Bodily In|ury 2 i offense the said B Xiang Zhang, not an 14 | accomplice to the above offense, within the meaning of Penal Code Sections 1203.075(a) and 15 | 12022.7. 16 17 ENHANCEMENT 3 18 2 PC190.2(a)(3): Special Circumstance-Multiple Murder 19 It is further alleged as to Count 1, Count 2, Count 3, Count 4, Coun} 6, Count 7 and Count 20 | 8 that the offenses charged in each of those counts are a special circumstance within the meaning of 21 | Penal Code Section 190.2(a)(3) (Multiple Murder). 22 NOTICE: Conviction of any of the above felony counts requires refinquishment of firearms, 23 | ammunition and ammunition feeding devices, 241 Pursuant to Penal Code Section 1054,5(b), the People are hereby ir.farmally requesting that. 2 | defontant(s) and his or her attomey provide to the People the discovery req. 3 4 g 6 7 8 9 10 18 19 20 2 2 23 24 2s red by Penal Code Section 1084.3. This is a continuing request pursuant to the provisions of Peral Code Section 1054.7. I declare under penalty of perjury that the foregoing is true and corrett except for those things stated on information and belief and those I believe to be true. Executed on January 25, 2023, at San Mateo County, California COMPLAINANT SM